United States Office of Air Quality £PA «53/R-97-O»
Environmental Protection Planning and Standards September 1997
Agency Research Triangle Park, NC 27711
_ _, - ,,
A Guide to the Wood
Furniture CTG and
NESHAP
IFMA
The Industry Voice tor WortpUct environment!'
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EPA 453/R-97-002
A GUIDE TO THE WOOD FURNITURE
CTG AND NESHAP
Coatings and Consumer Products Group
Emission Standards Division
Office of Air Quality Planning and Standards
U.S. Environmental Protection Agency
Research Triangle Park, NC 27711
Federal Small Business Assistance Program
Information Transfer and Program Integration Division
Office of Air Quality Planning and Standards
U.S. Environmental Protection Agency
Research Triangle Park, NC 27711
In Association With:
American Furniture Manufacturers Association
Business and Institutional Furniture Manufacturer's Association
Kitchen Cabinet Manufacturers Association
September 1997
The statements in this guidebook are intended solely as guidance. This guidebook is not intended, nor can it
be relied upon, to create any rights enforceable by any parry in litigation with the United States. Wood
furniture manufacturers should refer to 40 CFR part 63, subpart JJ and the Federal Register that will list
any proposed and/or final amendments to subpart JJ for applicable requirements.
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This report has been reviewed by the Office of Air Quality Planning and Standards
(OAQPS), U.S. Environmental Protection Agency (EPA), and approved for publication.
Mention of trade names or commercial products is not intended to constitute endorsement or
recommendation for use. For more information on this regulation, or to obtain additional
copies of this guidebook, please call your State Small Business Assistance Program; your
State Small Business Ombudsman; your State or local air pollution control agency; your
local, regional, or national wood furniture manufacturers trade association; or your EPA
Regional Office. Visit the EPA's Technology Transfer Network web site at
http://www.epa.gov/ttn to get information on your State small business programs, to
download an electronic version of this document, or to find additional materials concerning
this regulation. Copies of this guide are also available through the Library Services Office
(MD-35), U. S. EPA, Research Triangle Park, NC 27711.
H
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TABLE OF CONTENTS
Page
CHAPTER 1 INTRODUCTION 1-1
1.1 BACKGROUND 1-1
1.2 PURPOSE OF GUIDEBOOK 1-2
1.3 ORGANIZATION 1-3
CHAPTER 2 OVERVIEW OF THE CTG AND NESHAP 2-1
2.1 WOOD FURNITURE CTG - APPLICABILITY AND
REQUIREMENTS 2-1
2.2 WOOD FURNITURE NESHAP - APPLICABILITY AND
REQUIREMENTS 2-5
CHAPTER 3 WORK PRACTICE STANDARDS . .- 3-1
3.1 CTG AND NESHAP WORK PRACTICE STANDARDS ... 3-1
3.2 ADDITIONAL WORK PRACTICE STANDARDS FOR
THE NESHAP 3-5
,*''
CHAPTER 4 OPTIONS FOR COMPLYING WITH THE CTG AND
OPTIONS FOR COMPLYING WITH THE NESHAP 4-1
4.1 CTG COMPLIANCE OPTIONS 4-1
4.2 NESHAP COMPLIANCE OPTIONS 4-11
CHAPTER 5 RECORDKEEPING AND REPORTING REQUIREMENTS 5-1
5.1 RECORDKEEPING REQUIREMENTS 5-1
5.2 REPORTING REQUIREMENTS 5-6
CHAPTER 6 AVAILABLE CONTROL TECHNOLOGIES 6-1
6.1 REFORMULATED COATINGS , 6-1
6.2 ADD-ON CONTROL DEVICES . . .". 6-8
CHAPTER 7 OVERVIEW OF THE TITLE V OPERATING PERMIT
PROGRAM 7-1
7.1 BACKGROUND 7-1
7.2 INFORMATION TO BE INCLUDED IN AN OPERATING
PERMIT 7-1
7.3 REPORTING REQUIREMENTS ASSOCIATED WITH THE
OPERATING PERMIT 7-2
7 4 RELATIONSHIP TO THE CTG AND NESHAP 7-2
7.5 TIMEFRAME FOR SUBMITTING AN APPLICATION
FOR A PERMIT 7-4
in
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TABLE OF CONTENTS (continued)
Page
CHAPTER 8 DEVELOPING A POLLUTION PREVENTION PROGRAM AT
YOUR FACILITY 8-1
8.1 WHERE DO I START? 8-1
8.2 POLLUTION PREVENTION PRACTICES FOR THE
WOOD FURNITURE INDUSTRY 8-6
8.3 DEVELOPING AN OPERATOR TRAINING PROGRAM . . 8-13
APPENDIX A. ACRONYMS AND DEFINITIONS
APPENDIX B. LIST OF CONTACTS
APPENDIX C. OZONE NONATTAINMENT AREAS
APPENDIX D. DETAILED TABLE OF CONTENTS FOR THE NESHAP
APPENDIX E. LIST OF VOLATILE HAZARDOUS AIR POLLUTANTS
APPENDIX F. FEDERAL REGISTER NOTICE-WOOD FURNITURE NESHAP
APPENDIX G. EXAMPLE REPORTING FORMS
IV
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LIST OF FIGURES
Page
Figure 2-1. Determining the applicability of the CTG and NESHAP to your
facility 2-2
Figure 4-1. Example data sheet for spray booth operators 4-4
Figure 4-2. Example spreadsheet for calculating as applied VOC content
of coatings 4-4
Figure 8-1. Example checklist for documenting work practice standards are
being implemented 8-5
Figure 8-2. Example checklist for equipment inspection program 8-9
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LIST OF TABLES
TABLE 2-1. WOOD FURNITURE SIC CODES 2-3
TABLE 2-2. CTG REFERENCE CONTROL TECHNOLOGIES 2-4
TABLE 2-3. COMPLIANCE DATES FOR THE NESHAP 2-6
TABLE 2-4. SUMMARY OF NESHAP EMISSION LIMITS 2-7
TABLE 3-1. WORK PRACTICE STANDARDS FOR THE CTG AND NESHAP 3-2
TABLE 3-2. VHAP OF POTENTIAL CONCERN IDENTIFIED BY INDUSTRY 3-6
TABLE 4-1. COMPLIANCE METHODS FOR THE CTG AND NESHAP 4-1
TABLE 4-2. COMPLIANCE DEMONSTRATION FOR FACILITIES USING
COMPLIANT COATINGS 4-5
TABLE 4-3. COATING PARAMETERS FOR FACILITY AVERAGING
TOPCOATS 4-8
TABLE 4-4. COATING PARAMETERS AND USAGE FOR FACILITY USING
REVERSE HYBRID FINISHING SYSTEM 4-9
TABLE 4-5. OPERATING PARAMETERS FOR ADD-ON CONTROL
DEVICES 4-11
TABLE 4-6. COATING PARAMETERS FOR FACILITY USING AVERAGING
APPROACH TO MEET THE NESHAP EMISSION LIMITS FOR
FINISHING 4-15
TABLE 4-7. COMPLIANCE DEMONSTRATION FOR COMPLIANT
ADHESIVES 4-16
TABLE 5-1. RECORDKEEPING REQUIREMENTS FOR THE CTG 5-2
TABLE 5-2. RECORDKEEPING REQUIREMENTS FOR THE NESHAP 5-3
TABLE 5-3. RECORDKEEPING REQUIREMENTS FOR THE CTG AND
NESHAP WORK PRACTICE STANDARDS 5-5
TABLE 5-4. ADDITIONAL RECORDKEEPING REQUIREMENTS FOR
NESHAP WORK PRACTICE STANDARDS . . . 5-6
TABLE 5-5. INFORMATION INCLUDED IN INITIAL COMPLIANCE
REPORT FOR CTG 5-7
TABLE 5-6. INFORMATION TO BE INCLUDED IN SEMIANNUAL
COMPLIANCE STATUS REPORTS FOR THE CTG 5-9
TABLE 5-7. INFORMATION TO BE INCLUDED IN INITIAL COMPLIANCE
REPORT FOR THE NESHAP 5-10
TABLE 5-8. INFORMATION TO BE INCLUDED IN THE SEMIANNUAL
COMPLIANCE STATUS REPORT FOR THE NESHAP 5-11
TABLE 6-1. USING WATERBORNE FINISHING SYSTEMS TO MEET THE
CTG AND NESHAP EMISSION LIMITS 6-4
TABLE 7-1. WOOD FURNITURE FACILITIES REQUIRED TO OBTAIN A
TITLE V PERMIT 7.3
TABLE 7-2. ORIGINAL SCHEDULE FOR THE TITLE V PERMIT
PROGRAM 7.4
VI
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CHAPTER 1
INTRODUCTION
1.1 BACKGROUND
In December of 1995, the U.S. Environmental Protection Agency (EPA) issued
national emission standards for hazardous air pollutants (NESHAP) to control emissions from
wood furniture manufacturing operations. The regulation appeared in the December 7, 1995
edition of the Federal Register (volume 60, No. 235, beginning on page 62930), and was
codified as subpart JJ in 40 CFR Part 63. The level of emissions control required by the
NESHAP is based on the maximum achievable control technology (MACT). Therefore,
these standards are sometimes referred to as MACT standards.
The Clean Air Act as amended in 1990 (CAA) directs the EPA to regulate emissions
of 189 toxic chemicals (hazardous air pollutants (HAP)) from a wide range of industrial
sources. In 1992, surface coating of wood furniture was listed as a source category to be
regulated under the CAA because many of the coatings, adhesives, and solvents used in the
wood furniture industry contain toxic chemicals such as toluene, xylene, methanol, methyl
ethyl ketone, glycol ethers, and formaldehyde. Therefore, the EPA is regulating HAP
emissions from wood furniture manufacturing facilities to meet the requirements of the CAA.
The EPA estimates that this regulation will reduce nationwide HAP emissions from wood
furniture manufacturing facilities by 32,000 tons per year.
On May 20, 1996 (60 FR 25223), EPA issued a Control Techniques Guidelines
(CTG) document that recommends reasonably available control technology (RACT) for
reducing volatile organic compound (VOC) emissions from wood furniture finishing and
cleaning operations. State and/or local agencies may use these guidelines to establish their
own regulations based on EPA's recommendation for RACT.
The goals of the NESHAP and CTG are different. The goal of the NESHAP is to
reduce HAP emissions from wood furniture manufacturing facilities located nationwide,
while the goal of the CTG is to reduce VOC emissions from wood furniture facilities located
only in areas classified as ozone nonattainment (see Appendix C). However, because many
1-1
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of the coatings and solvents used by the wood furniture industry contain chemicals that are
both VOC and HAP, the goals of the two programs overlap.
Both the NESHAP and the CTG were developed through a regulatory negotiation
process. In a regulatory negotiation, EPA works with members of industry, State
representatives, and representatives from environmental groups to try to reach an agreement
regarding the level of control that should be required, the format of the standards,
compliance options, and recordkeeping and reporting requirements. The wood furniture
regulatory negotiation Committee reached consensus on all issues.
1.2 PURPOSE OF GUIDEBOOK
The purpose of this guidebook is to provide a straightforward overview of the wood
furniture manufacturing NESHAP to equip businesses with the basic information they need to
comply with the regulation. This guidebook is not a complete and full statement of the legal
and technical requirements of the regulation. See 40 CFR Part 63, Subpart JJ (Appendix Fr*
of this guidebook) for the complete text of the regulation.
This guidebook also presents an overview of the recommended, or presumptive,
RACT requirements. Throughout the manual, these will be referred to as the CTG
requirements. However, the CTG is only a guidance document that contains a model rule
for States to use in developing their own rules. Because State requirements may vary from
the CTG requirements presented in this manual, wood furniture manufacturers should contact
their State or local agency to obtain a copy of the applicable rule for their facility and
familiarize themselves with the requirements of that rule.
This manual also includes summary tables and example calculations that are designed
to assist you in understanding and complying with the wood furniture NESHAP. Example
recordkeeping and reporting forms are also included that you can adapt to your own
operations.
The EPA may revise this guidebook without public notice to reflect any future
amendments to the Wood Furniture NESHAP, or to clarify and update text as appropriate.
Any proposed and final amendments to the Wood Furniture NESHAP will be published in
the Federal Register, which will include the effective date of such amendments.
Accordingly, affected sources should review Federal Register notices to determine whether
1-2
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the Wood Furniture NESHAP has been amended after the date of this Guidebook, or after
the date of publication of their edition of the Code of Federal Regulations containing the
.NESHAP (40 CFR Part 63, Subpart JJ).
1.3 ORGANIZATION
Chapter 2 of this guidebook presents an overview of the NESHAP and CTG
applicability and requirements. Chapters 3,4, and 5 discuss the work practice standards,
compliance options, and recordkeeping and reporting requirements, respectively. Available
control technologies are discussed in Chapter 6, while Chapter 7 presents an overview of the
Title V operating permit program. Finally, Chapter 8 presents pollution prevention options
and discusses how to develop a pollution prevention program. The appendices contain
acronyms and definitions, contacts, a listing of designated ozone nonattainment areas, a
detailed table of contents for the NESHAP, a list of volatile hazardous air pollutants
(VHAP), the text of the wood furniture manufacturing NESHAP, and example reporting
4
forms.
1-3
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CHAPTER 2
OVERVIEW OF THE CTG AND NESHAP
2.1 WOOD FURNITURE CTG - APPLICABILITY AND REQUIREMENTS
As discussed in the introduction, the CTG serves only as a guideline that State and/or
local agencies may use in developing their own rules. (Throughout the remainder of the
manual we will refer to States only. However, the reader should be aware that in some
cases a local agency may be the implementing agency rather than the State.) The CTG
includes a recommendation for a presumptive norm for RACT. Any State rules must be as
stringent as the presumptive norm for RACT. However, in many cases there is nothing that
precludes the State from making their own rules more stringent.
2.1.1 Applicability of the CTG
Figure 2-1 can be used to assist facilities in determining whether they are subject to
the CTG, NESHAP, neither, or both. The CTG is applicable to wood furniture
manufacturing facilities located in ozone nonattainment areas, or in the ozone transport
•region, that emit or have the potential to emit 25 tons or more of volatile organic compounds
(VOC). The applicability cutoff is even lower for facilities located in extreme nonattainment
areas. (Currently, the only extreme nonattainment area is the Los Angeles, California area.)
Wood furniture manufacturing facilities located in extreme ozone nonattainment areas that
emit or have the potential to emit 10 tons or more of VOC are subject to RACT.
Appendix C contains a current listing of ozone nonattainment areas. However, this list is
continually changing, so you should contact your State or local agency to determine the
current status of your area.
The EPA defines wood furniture manufacturing facilities as those operating under the
^standard industrial classification (SIC) codes presented in Table 2-1. The EPA considers
facilities manufacturing these products, or components of these products, to be wood
furniture manufacturing facilities. Three of these SIC codes, 2519, 2531, and 2599, include
facilities manufacturing nonwood products. For example, SIC 2531 includes manufacturers
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IS THE FACILITY LOCATED M AM
OZONE NONATTAMMENT AREA OR
THE OZONE TRANSPORT RBSDN?
NO
FACUTVIS NOT (OBJECT
TO THE CTO BUT MAY BE
MUKTTDlTMNflSHAP
YES
DOBS THE MCttJTVEMrr OR HAVE
THEPOTBmALTOEMfT2STONSOF
WCrtH (10TON9/YRIFUOCATED M
AN EXIHEME HONATTAIIMDIT
AREA)}
NO
FACUTY IS NOT
SUBJECT TO THE CTB
BUT MAYBB SUBJECT
TOTHENESHAr
YES
FACUTY IS SUBJECT TO THE CTO.
AND THEY SHOULD CONTACT THEIR
STATE OH LOCAL AQENCY FOR A
COPY OF STATE REGULATIONS
BASED ON THE CTS
IS THE FACIUTY AN ll«IDENTALRJHNmOT MANUFACTURER USING LESS
THAN tOO aAUUO OF WOOD FURNTIURE COATN3S AND ADHE3IVE3 BUT
A MAJORSOURCE DUE TO OTHER OPERATIONS?
YES
FACUTY IS NOT SUBJECT-TO NESHAP BUT
MUST MAINTAIN COATW6 AND ADHESIVE
USAGE RECORDS
NO
DOES THE FACILITY USE MORE THAN 250 SAL/MO (3,000 SAL PER ROLLING
12-MONTH PERIOD) OF F1MSHNQ, QLUNQ, CLEANINQ, AND WAfiHOFF
MATERIALS flNCLUDINQ MATERIALS USED W PflOCESSES OTHER THAN
WOOD FURNTTURE MANUFACTUSINQJt
OR
DOES THE FACIUTY USE MATERIAL* CONTAIWNQ MORE THAU 5 TONS OF
ANYONE HAP PER ROLLWQ12 MONTH PB»OO OR MOFETKAN
124 TONS OF ANY COMBINATION OF HAP PER ROUJNS 12 UDMTH PER ICO
(INCLUDING MATERIALS USED N PROCESSES OTHER THAN WOOD
FURNITURE UANUFACTURINfi)?
NO
FACIUTY IS AN AREA SOURCE AND IS NOT
SUBJECT TO THE NESHAP F M PERCENT OF
TOTAL EMISSIONS FROM THE SITE ARE
FROM MATERMLS USED FOR WOOD
FURMTUne MANUFACTURE OPERATIONS.
THE FACUTY MUST MAINTAIN ftCCOftfiS OP
THE AMOUNT OF MATERIALS USED AND
OPDS FOR THOSE MATERIALS.
YES
DOES THE FACILnY EMTT OR HXVETHE POTEMTIALTO EMIT 10 TONS
OF ANYONE HAP OR 2S TONS OF A COMBINATION OF HAP-i PER YEAR
(INCLUDING EMISSIONS FROM PROCESSES OTHER THAN WOOD
FURNITURE MANUFACTUWNO)?
NO
YES
FACUirr IS NOT SUBJECT TO THE NESHAP.
BUT THEY MAY HAVE TO OBTAM A
PEDERAU.Y ENFORCEABtf UUrr ON THEIR
POTENTIAL TO EMIT BY UMmNQTHBR
OPERATING HOURS. OOATMB USAQt ETC.
FACIUTY IS SUBJECTTO THE NECHAP
WO CONSTRUCTION OR RECONSTRUCTION OF THE FACILITY BBQM AFTER
DECEMBER (.ItM
YES
FACUTY IS A NEW SOURCE AND IS SUBJECT
TO THE EMISSION UMTTS POR NEW.
SOURCES
NO
FAdUTY IS AN EX/STING SOURCE AND IS SUBJECT TO THE EMISSION UMfTS
PCR EMSTM6 SOURCES
Figure 2-1. Determining the applicability of the CTG and NESHAP to your facility.
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of seats for automobiles and airplanes. These facilities will not be subject to the CTG,
because they are not wood furniture manufacturers.
TABLE 2-1. WOOD FURNITURE SIC CODES
SIC code
2434
2511
2512
2517
2519
2521
2531
2541
2599
5712
Industry
Wood kitchen cabinets
Wood household furniture
Upholstered household furniture
Wood television and radio cabinets
Household furniture, not elsewhere classified
Wood office furniture
Public building and related furniture
Wood partitions and fixtures
Furniture and fixtures, not elsewhere
classified
Furniture stores
Typical products
Cabinets (to be built-in)
Cabinets (factory made)
Vanities
Beds, bookcases, chairs, dressers, stools,
tables
Chairs, sofas
Television cabinets, sewing machine
cabinets, stereo cabinets
Bassinets; reed, rattan, and other wicker
furniture, garden and lawn furniture
Desks, filing cabinets, bookcases, chairs
Benches, bleachers, church furniture
Shelves, lockers, office and store fixtures,
prefabricated partitions
Furniture for hospitals, restaurants, bowling
centers, and ships
Custom made cabinets
While these SIC codes represent the majority of facilities that EPA considers wood
furniture manufacturers, States may choose^to extend the^r rulQS together operations. For
example, some States have developed rules for manufacturers of wood products so they may
include limitations for manufacturers of items such as musical instruments or doors.
2.1.2 Compliance Date
States must provide for affected sources to install and operate the required control
devices or implement the required procedures in the presumptive norm for RACT no later
than May 20, 1998.
2.1.3 CTG Reference Control Technologies
The CTG identifies two reference control technologies as presumptive RACT. The
reference control technologies include emission limitations for topcoats or for sealers and
topcoats, expressed as a limitation on the pounds of VOC emitted per pound of solids used
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(Ib VOC/lb solids) for these coatings. The two reference control technologies are presented
in Table 2-2.
TABLE 2-2. CTG REFERENCE CONTROL TECHNOLOGIES
AND CORRESPONDING EMISSION LIMITS
Reference control technology
Finishing operations
Waterborne topcoats
Higher solids sealers and topcoats
- Sealers
- Topcoats
- Acid-cured alkyd amino
vinyl sealers
- Acid-cured alkyd amino
conversion varnishes
Cleanine operations
Waterborne strippable spray booth coating
VOC limit, Ib
VOC/lb solids'
0.8
1.9
1.8
2.3
2.0
0.8
"Represents VOC limit as applied, that is, including the
contribution of thinners or other solvents added to the
coating.
A facility may choose to use either of the reference control technologies to meet the
RACT requirements. The CTG also limits the VOC content of strippable spray booth
coatings to 0.8 Ib VOC/lb solids, as applied.
While waterborne topcoats and higher solids sealers and topcoats are the reference
control technologies, facilities may choose to use methods other than these to comply with
the rule. The model rule that EPA developed based on the CTG allows facilities to use a
compliant coatings approach, an averaging approach, an add-on control device, or a
combination of methods as long as they are achieving an emission reduction greater than or
equal to that achieved by the reference control technologies. Chapter 4 includes a detailed
discussion of these compliance methods, including example calculations for determining
equivalency.
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2.2 WOOD FURNITURE NESHAP - APPLICABILITY AND REQUIREMENTS
The level of control required by th&.NESHAP»is based onJvlAdV Unlike RAQT,
which addresses VOC emissions, MACT is aimed at reducing emissions of hazardous air
pollutants (HAP). While the majority of HAP are VOC, not all VOC are HAP.
Appendix E contains a list of volatile HAP (VHAP) that will be regulated under this
NESHAP.
In addition to regulating VHAP emissions from finishing and cleaning operations, the
NESHAP will also regulate emissions from some gluing operations. The NESHAP includes
emission limitations for contact adhesives, and many of the work practice standards that are
discussed in Chapter 3 also apply to gluing operations."
2.2.1 Applicability of NESHAP
The NESHAP is a national standard that applies to wood furniture manufacturing
facilities that emit or have the potential to emit 10 tons or more of any HAP or 25 tons or
more of any combination of HAP. These sources are known as major sources. Wood
furniture facilities are defined as they are for the CTG (see Table 2-1). However, in
determining whether or not a source is major, HAP emissions from all sources at the facility
must be accounted for. For example, a facility may manufacture metal and wood furniture.
^Although the NESHAP will only apply to the wood furniture manufacturing operations,
emissions from the metal furniture manufacturing operations must be included when
determining whether or not the source is major.
However, if a facility only performs incidental wood furniture manufacturing but is a
major source due to other unrelated activities, the facility is not subject to the regulation if
no more than 100 gallons per month of wood furniture coatings and adhesives are used. This
exemption would include operations such as hobby shops on military bases or maintenance
^.shops at chemical plants that manufacture wood furniture items such as bookshelves for on
'site use. These facilities must maintain records to demonstrate that their usage of wood
furniture coatings and adhesives is no more than 100 gallons per month.
Sources using less than 250 gallons per month, or 3,000 gallons per rolling 12-month
period, of coating, gluing, cleaning, and .washoff materials-, including materials used for
operations other than wood furniture manufacturing, are area sources and are not subject to
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the NESHAP if the finishing materials, adhesives, cleaning solvents, and washoff solvents
account for at least 90 percent of annual emissions at the plant site. These sources must also
maintain records that demonstrate their material usage is below these levels. A rolling
12 month period includes the previous 12 months of operation at the facility. Facilities
should note that this limitation includes all coating, gluing, cleaning, and washoff materials,
whether those materials contain HAP or not.
Sources that use materials containing no more than 5 tons per rolling 12 month period
of any one HAP or 12.5 tons per rolling 12 month period of any combination of HAP are
also considered area sources under the NESHAP. These facilities will be required to
maintain records demonstrating that their actual emissions are less than these cutoffs.
2.2.2 Compliance Dates
Table 2-3 presents the compliance dates for existing facilities subject to the NESHAP.
An existing facility's compliance date is determined by-its actual emissions forthe-year -1996.
New sources must comply with the provisions of the NESHAP upon promulgation of the
NESHAP or upon startup, whichever is later. For this rule, facilities are considered new
sources if construction commenced on or after December 6, 1994.
TABLE 2-3. COMPLIANCE DATES FOR THE NESHAP
FOR EXISTING SOURCES
Emissions
<50 tons of HAP/yr
> 50 tons of HAP/yr
Compliance date
December 7, 1998
November 21, 1997
2.2.3 NESHAP Emission Limitations
A summary of the NESHAP emission limitations is presented in Table 2-4. These
include limitations on the VHAP content of both finishing materials and contact adhesives
and a limit on the VOC content of strippable spray booth coatings.
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TABLE 2-4. SUMMARY OF NESHAP EMISSION LIMITS
Emission point
Finishing operations
(a) Achieve a weighted average VHAP content across all coatings
Ob VHAP/lb solids, as applied);
(b) Use compliant finishing materials Ob VHAP/lb solids, as
applied)
-stains
-washcoats
-sealers
-topcoats
-basecoats
-enamels
-thinners (maximum %VHAP)
(c) Use a control device; or
(d) Use a combination of (a), (b), and (c)
Cleaning operations
Strippable spray booth coating (Ib VOC/lb solids, as applied)
Gluing operations
(a) Use compliant contact adhesives (Ib VHAP/lb solids, as
applied) based on the following criteria:
i. For aerosol adhesives, and for contact adhesives applied
to nonporous substrates
ii. For foam adhesives used in products subject to
flammability testing;
iii. For all other contact adhesives (including foam adhesives
used in products not subject to flammability testing but
excluding aerosol adhesives and excluding contact
adhesives used on nonporous substrates); or
(b) Use a control device
Existing source1
1.0
1.0
1.0"
1.0
1.0
1.0"
1.0"
10.0
1.0e
1.0
0.8
NAd
1.8
1.0
1.0'
New source*
0.8
1.0
0.8"
0.8
0.8
0.8"
0.8b
10.0
0.8C
0.8
0.8
NA"
0.2
0.2
0.2e
•The limits refer to the maximum VHAP/VOC content, as applied.
bWashcoats, basecoats, and enamels must comply with the limits presented in this table if they are
purchased premade, that is, if they are not formulated onsite by thinning other finishing materials. If
they are formulated onsite, they must be formulated using compliant finishing materials (i.e., those that
meet the limits specified in this table) and thinners containing no more than 3.0 percent VHAP by
weight.
The control device must operate at an efficiency that is equivalent to no greater than 1.0 pound of VHAP
(0.8 for new sources) being emitted per pound of solids used.
"There is no limit on the VHAP content of these adhesives.
The control device must operate at an efficiency that is equivalent to no greater than 1.0 pound of VHAP
(0.2 for new sources) being emitted per pound of solids used.
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Note that the NESHAP includes emission limitations for both existing and new
stJurcfes. • Wob\Mbr«ititttTnantfaei^ begin construction or reconstruction
after the proposal date, that is, after December 6, 1994, are considered new sources.
Reconstruction is the replacement of components of a source to the extent that the fixed
capital cost of the new components exceeds 50 percent of the fixed capital cost that would be
required to construct a comparable new source.
As with the CTG, there are several options a facility may use to comply with the
emission limits for finishing operations. Chapter 4 provides additional detail on each of the
compliance methods, including examples of the calculations to be used to demonstrate
compliance.
The standards for finishing operations limit the pounds of VHAP per pound of solids
for selected coatings or as an average across all coatings used at the facility. Because many
facilities formulate their washcoats, basecoats, and enamels onsite by thinning other types.p/
finishing materials (for example, many facilities thin their sealers to use as washcoats) the
regulation contains guidance that is aimed at reducing the recordkeeping burden on these
facilities. If the facility does formulate these coatings onsite, then it will be deemed
compliant as long as the finishing material that is thinned is compliant and thinners with a
VHAP content of no more than 3.0 percent are used to thin the coating. For example, if a
facility thins its sealer to make washcoat, the facility does not have to maintain records of the
VHAP content^rf-the washcoat as long as the sealer has a VHAP content of no more than
1.0 Ib VHAP/lb solids (0.8 for new sources) and the thinner has a VHAP content no greater
than 3.0 percent by weight. If the facility purchases washcoat, however, it must demonstrate
that the washcoat is compliant.
Contact adhesives are the only type of adhesive regulated by the standard. In the
regulation, foam adhesives are considered a subset of contact adhesives, and they have a
different emission limitation depending upon whether the product in which they are used is
subject to flammability testing. Foam adhesives used in products subject to flammability
testing, which is often required for office and institutional furniture, have a less stringent
emission limit because testing has shown that products made with waterborne adhesives may
not pass the flammability tests. However, foam adhesives used by new sources must meet
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the same emission limit as all other contact adhesives, regardless of any flammability testing
that may be required. Note that aerosol adhesives and contact adhesives used on nonporous
substrates (rubber, metal, rigid plastic, and flexible vinyl) are not subject to emission limits
under this rule.
2-9
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CHAPTERS
WORK PRACTICE'STANDARDS
Work practice standards are an integral part of both the CTG and the NESHAP. In
general, the work practice standards are aimed at reducing coating, cleaning solvent, and
washoff solvent usage. Many facilities will have already implemented a number of these
work practices because, in addition to reducing emissions, they also reduce worker exposure
to solvents and, in many cases, operating costs. Most of the work practice standards are
common to both the CTG and the NESHAP, although a few are associated with the
NESHAP only. Section 3.1 includes a discussion of the work practice standards that are
common to both the CTG and NESHAP, while Section 3.2 addresses those work practice
standards that are required by the NESHAP only.
J.I CTG AND NESHAP WORK PRACTICE STANDARDS
A summary of the work practice standards that are required by both the CTG and
NESHAP is presented in Table 3-1. Chapter 5 includes a discussion of recordkeeping and
reporting requirements associated with the work practice standards. Guidance on developing
a site-specific pollution prevention program, which should include the work practice
standards presented here, is provided in Chapter 8. Also included in Chapter 8 is a
discussion of elements that should be included in an operator training program, one of the
work practice standards required by both the CTG and NESHAP**
Following is a brief discussion of each of the work practice standards.
3.1.1 Application Equipment Requirements
Both the CTG and the NESHAP limit the use of conventional air spray guns.
Facilities are allowed to use these guns only under any of the following conditions:
1. If they are using the guns to apply coatings that have a VOC content no greater
than 1.0 Ib VOC/lb solids, as applied;
2. If they are using the gun for touchup and repair that occurs either after the
completion of the finishing operation or after the application of stain and before the
application of other types of finishing materials, rn addition, any materials used for touchup
3-1
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TABLE 3-1. WORK PRACTICE STANDARDS FOR THE CTG AND NESHAP3
Emission source
Work practice
Finishing operations
Equipment leaks
Storage containers, including mixing
equipment
Application equipment
Develop a written inspection and maintenance plan to address
and prevent leaks. Inspections must be made once per month.
Keep containers used for storing or mixing VOC or HAP, or
materials containing VOC or HAP, covered when not in use.
Discontinue use of conventional air spray guns.b
Cleaning and washoff operations
Gun/line cleaning
Spray booth cleaning
Washoff/general cleaning
- Collect solvent into a closed container.
- Cover all containers associated with cleaning when not in
use.
Use solvents for cleaning spray booths only under certain
conditions.1
- Keep washoff tank covered when not in use.
- Minimize dripping by tilting and/or rotating the pan to drain
as much solvent as possible. Allow sufficient dry time for
the pan.
- Maintain a log of the number of parts washed off and the
reason for the washoff.
- Maintain a log of the quantity and type of solvent used for
washoff and cleaning, as well as the quantity of solvent
reused for other operations at the facility and the quantity of
solvent sent offsite for disposal.
Miscellaneous
Operator training
Implementation plan
All operators shall be given annual training on proper
application methods, cleaning procedures, and equipment use.
Develop a plan to implement these work practice standards and
maintain onsite.
'The work practice standards apply to both existing and new major sources.
""Conventional air spray guns will be allowed only in any of the following instances:
- when they are used to apply finishing materials that emit less than 1.0 Ib VOC/lb solids;
- touchup and repair under limited conditions;
- when spray is automated;
- when add-on controls are employed;
- if the cumulative application is no more than 5.0 percent of the total gallons of finishing material
applied; or
- if the permitting agency determines that it is economically or technologically infeasible to use other
application technologies.
cSolvents can be used for cleaning conveyors and their enclosures and metal filters. Limited quantities, no
more than 1.0 gallon, can also be used for spot cleaning when the spray booth coating is being replaced.
3-2
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and repair after the stain application must be applied from a container with a volume of no
more,than-2.0 gallons.
3. If the guns are automatic;
4. If the guns are used in a spray booth or other application station where emissions
are directed to a control device;
% 5. If the guns are only used for applying small quantities of finishing material. The
total amount of finishing material applied with the conventional air spray gun must be no
more than 5.0 percent of the total amount of finishing material used in that semiannual
period; or
6. If the gun is used to apply stain and the facility can demonstrate that it is
technically or economically infeasible to use another spray application technology.
To qualify for exemption (6), the facility must submit a videotape, a technical report,
or some other type of documentation to the permitting agency that supports the facility's
claim of technical or economic infeasibility. There are two factors that the facility can use
either singly or in combination to support their claim. These are:
1. The production speed is too high or the part shape is too complex for one operator
to finish the part and the spray booth is not large enough for an additional operator; or
'••> 2. The part has an excessively large vertical spray area, making it difficult to avoid
sagging or runs in the stain.
A final determination of whether the facility may use the conventional air spray gun under
exemption (6) will be made by the permitting authority.
3.1.2 Operator Training Program
Each facility subject to the CTG or NESHAP must train all employees who are
involved in finishing, gluing, cleaning, or washoff operations annually. All personnel hired
'-before the effective date of the standard, which will vary according to the size of the facility
for the NESHAP and will be based upon the date established by the States in their rules that
are based on the CTG, must be trained within 6 months of the effective date. Personnel who
are hired after the effective date of the standard must be trained upon hiring. All personnel
must be retrained annually.
3-3
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Operator training should include instruction in application techniques, cleaning and
washoff procedures, equipment .setup and adjustment, and management of waste solvent from
cleaning and washoff operations. The facility must develop a training program that includes
a list of current personnel that must be trained, an outline of the subjects covered in the
initial and refresher training, and a description of how the facility will document that
personnel have successfully completed the training program.
3.1.3 Inspection and Maintenance Plan
Each facility must also develop an inspection and maintenance plan that addresses
equipment leaks. Facilities are required to visually check all equipment used to transfer or
apply finishing materials or organic solvents at least once a month to ensure there are no
equipment leaks. The inspection and maintenance plan should include a schedule for
inspections and a way to document the date of each inspection as well as any repairs that
were made. After identifying the leak, the facility must attempt to repair the leak within
5 days and make final repairs within 15 days, unless the leaking equipment has to be
replaced, in which case the facility is allowed 3 months to complete repairs.
3.1.4 Cleaning and Washoff Solvent Accounting Program
Facilities are required to develop a program for tracking the amount and type of
organic solvent used for cleaning and washoff each month. They must also track the amount
of spent solvent that is generated from each cleaning operation each month, the amount of
that spent solvent that is reused in-house for operations other than cleaning or washoff, and
the amount that is sent off site for disposal. Finally, the program should provide a
mechanism for tracking the number of pieces that are washed off and the reason for the
washoff.
3.1.5 Additional Work Practice Standards
3.1.5.1 Spray Booth Cleaning. The CTG and NESHAP limit the types of cleaners
that can be used for spray booth cleaning. Unless operators are cleaning conveyors,
continuous coaters and their enclosures, or metal filters, they may not use cleaning
compounds containing more than 8.0 percent of VOC by weight. The 8.0 percent limit
should still allow facilities to use many commercial cleaners, but it precludes the use of
organic solvent. Facilities may, however, use organic solvents in small quantities, no more
3-4
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than 1.0 gallon per booth, if they are replacing the strippable spray booth coating or other
protective materialised to cover the booth,,.
3.1.5.2 Storage Containers. All containers that are used to store finishing, cleaning,
or washoff materials must be closed unless an operator is emptying or filling the container.
This includes drums that are used to-hold wiping rags.
3.1.5.3 Gun and Line Cleaning. Organic solvent used to clean spray guns and lines
must be collected in a container that is kept closed except when an operator is emptying or
filling the container.
3.1.5.4 Washoff Operations. Tanks used for washoff must be kept closed when they
are not being used. Operators should also try to minimize dripping from the part that has
been washed off by tilting or rotating the part so that the solvent can drain back into the
tank.
3.1.6 Work Practice Implementation Plan
Each facility must develop a work practice implementation plan that documents how
they will ensure that all of the work practice standards are being followed. The operator
training program, the inspection and maintenance plan, and the solvent accounting program
should be included in the work practice implementation plan along with examples of record
forms or checklists developed by the facility as a part of these plans. Facilities should
develop checklists that employees can use to document the results of facility-wide
inspections. For example, facilities should have someone conduct frequent inspections of the
facility to ensure that storage containers are closed, solvent used for gun and line cleaning is
being collected in a closed container, and washoff tanks are closed. Chapter 8 includes
examples of checklists facilities may want to use.
3.2 ADDITIONAL WORK PRACTICE STANDARDS FOR THE NESHAP
The NESHAP has two work practice standards that are not required by the CTG. In
addition, the work practice standard requiring that containers used for storing finishing,
cleaning, and washoff materials remain closed is extended to include containers used to store
adhesives. The major work practice standard required by the NESHAP that is not required
by the CTG is the formulation assessment plan for finishing operations.
3-5
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3.2.1 Formulation Assessment Plan for Finishing Operations
Table 3-2 presents a partial'list of what the regulation refers to as VHAP of potential .
concern. These VHAP of potential concern were identified by several coating suppliers as
being present in some coating formulations used by the wood furniture industry. The first
step for the facility in developing their formulation assessment plan is to identify any
chemicals from this list that are used in their finishing materials or thinners. The facility
must then determine how much of the chemical they used in 1994, 1995, and 1996. The
highest value from those 3 years is considered the baseline level of usage for that chemical.
Note that VHAP of potential concern used in adhesives should not be included in the baseline
level. The formulation assessment plan only applies to" VHAP of potential concern used in
finishing materials.
TABLE 3-2. VHAP OF POTENTIAL CONCERN IDENTIFIED BY INDUSTRY
Chemical
Dimethyl formamide
Formaldehyde
Methylene chloride
2-Nitropropane
Isophorone
Styrene monomer
Phenol
Diethanolamine
2-Methoxyethanol
2-Ethoxyethyl acetate
CAS No.
68122
50000
75092
79469
78591
100425
108952
11422
109864
111159
EPA de minimis,
tons/yr
1.0
0.2
4.0
1.0
0.7
1.0
0.1
5.0
10.0
5.0
Sources using a control device to reduce emissions should adjust their usage based on
the overall control efficiency of the control system. Because some portion of the
formaldehyde and styrene in a coating becomes part of the cured resin, the regulation
provides guidance on how to calculate usage of these chemicals. For formaldehyde, usage is
based on the amount of free formaldehyde present in the finishing material when it is
3-6
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applied. For styrene monomer, usage is calculated by multiplying the amount of styrene
monomer in the finishing material when it js applied by a factor o£ 0.16.
Facilities must continue to track their usage of each VHAP of potential concern.
However, they only have to track usage of those VHAP that are present in a finishing
material in a large enough quantity that it must be reported on the material safety data sheet
(MSDS). If, after November 1998, a facility's usage of the VHAP exceeds the baseline
usage level for that VHAP, the facility must notify the permitting authority in writing that
they have exceeded their baseline level, the amount by which they have exceeded the
baseline, and the reasons why. If the facility has exceeded the baseline for any of the
reasons cited below, and they are in compliance with any State regulations or requirements
for that VHAP, the facility does not have to take any further action.
1. The exceedance is no more than 15.0 percent above the baseline level;
i. 2. The facility's usage of the VHAP is less than the de minimis value for that VHAP
as presented in Table 3-2;
3. The facility is in compliance with its State's air toxics regulations or guidelines for
that VHAP; or
4. The VHAP is being used in a finishing material with a VOC content of no more
than 1.0 Ib VOC/lb solids, as applied.
If the increase above the baseline level is due to some reason other than those listed
above, the facility must then refer to their permitting authority to*discuss the reason for the
increase and whether or not there are practical and reasonable technology-based solutions for
reducing the usage. Cost, quality, and marketability of the product, as well as successful
usage of the technology by other wood furniture manufacturers, may all be considered in
determining whether a solution exists. The facility and the permitting authority may also
•agree upon other factors that should be used for such an evaluation. If there are no practical
and reasonable solutions, the facility would not have to take any further action. If there are
solutions, the facility must develop a plan to reduce usage of the VHAP to the extent
feasible. The plan should address the approach the facility will use to reduce usage, a
timetable for reducing usage, and a schedule for reporting progress to the permitting
authority.
3-7
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There may be cases in which a facility begins using a VHAP of potential concern for
which a baseline level has not been previously-established. In those-cases, the baseline4evel
is equal to the de minimis level, based on 70 year exposure levels and data provided in the
proposed rulemaking pursuant to section 112(g) of the Clean Air Act, for that VHAP. A
complete listing of all VHAP of potential concern is presented in Table-A-1. If usage of .the
VHAP is greater than the de minimis level, then the facility must follow the same procedures
as those in the previous paragraphs for exceeding an established baseline level. Any of the
reasons listed in (1) through (4) will excuse the facility from further action.
3.2.2 Composition of Cleaning and Washoff Solvents
The NESHAP also prohibits the use of solvents containing any of the chemicals listed
in Table 3-3 for cleaning and washoff operations. However, the restriction is only limited to
chemicals that are present in the solvent at a level high enough that they have to be reported
-ontheMSDS.
3-8
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TABLE 3-3. POLLUTANTS EXCLUDED FROM USE IN
CLEANING AND WASHOFF SOLVENTS
Chemical Name
CAS No.
4-Aminobiphenyl
Styrene oxide
Diethyl sulfate
N-Nitrosomorpholine
Dimethyl formamide
Hexamethylphosphoramide
Acetamide
4,4' -Methy lenedianiline
o-Anisidine
2,3,7,8 -Tetrachlorodibenzo-p-dioxin
Beryllium salts
Benzidine
N-Nitroso-N-methylurea
Bis(chloromethyl)ether
Dimethyl carbamoyl chloride
Chromium compounds (hexavalent)
1,2-Propylenimine (2-Methyl aziridine)
Arsenic and inorganic arsenic compounds
Hydrazine
1,1 -Dimethyl hydrazine
Beryllium compounds
1,2-Dibromo-3-chloropropane
N-Nitrosodimethylamine
Cadmium compounds
Benzo (a) pyrene
Polychlorinated biphenyls (Aroclors)
Heptachlor
3,3'-Dimethyl benzidine
Nickel subsulfide
Acrylamide
Hexachlorobenzene
Chlordane
1,3-Propane sultone
1,3-Butadiene
Nickel refinery dust
2-Acetylaminoflourine
3,3' - Dichlorobenzidine
Lindane (hexachlorcyclohexane, gamma)
2,4-Toluene diamine
Dichloroethyl ether (Bis(2-chloroethyl)ether)
1,2 Diphenylhydrazine
Toxaphene (chlorinated camphene)
2,4-Dinitrotoluene
92671
96093
64675
59892
68122
680319
60355
101779
90040
1746016
92875
684935
542881
79447
75558
99999904
302012
57147
7440417
96128
62759
50328
1336363
76448
119937
12035722
79061
118741
57749
1120714
106990
53963
53963
58899
95807
111444
122667
8001352
121142
3-9
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TABLE 3-3. (continued)
Chemical Name
CAS No.
3,3'-Dimethoxybenzidine
Formaldehyde
4,4'-Methylene bis(2-chloroaniline)
Acrylonitrile
Ethylene dibromide(l,2-Dibromoethane)
DDE (1,1-p-chlorophenyl 1-2 dichloroethylene)
Chlorobenzilate
Dichlorvos
Vinyl chloride
Coke Oven Emissions
Ethylene oxide
Ethylene thiourea
Vinyl bromide (bromoethene)
Selenium sulfide (mono and di)
Chloroform
PentachloTophenol
Ethyl carbamate (Urethane)
Ethylene dichloride (1,2-Dichloroethane)
Propylene dichloride (1,2-Dichloropropane)
Carbon tetrachloride
Benzene
Methyl hydrazine
Ethyl acrylate
Propylene oxide
Aniline
l,4-Dichlorobenzene(p)
2,4,6-Trichlorophenol
Bis(2-ethylhexyl)phthalate (DEHP)
o-Toluidine
Propoxur
Trichloroethylene
1,4-Dioxane (1,4-Diethyleneoxide)
Acetaldehyde
Bromoform
Captan
Epichlorohydrin
Methylene chloride (Dichloromethane)
Tetrachloroethylene (Perchloroethylene)
Dibenz (ah) anthracene
Chrysene
Dimethyl aminoazobenzene
Benzo (a) anthracene
Benzo (b) fluoranthene
Antimony trioxide
119904
50000
101144
107131
106934
72559
510156
62737
75014
99999908
75218
96457
593602
7488564
67663
87865
51796
107062
78875
56235
71432
60344
140885
75569
62533
106467
88062
117817
95534
114261
79016
123911
75070
75252
133062
106898
75092
127184
53703
218019
60117
56553
205992
1309644
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TABLE 3-3. (continued)
Chemical Name
CAS No.
2-Nitropropane
1,3-Dichloropropene
7, 12-DLmethylbenz(a)anthracene
Benz(c)acridine
Indeno(l ,2,3-cd)pyrene
l,2:7,8-Dibenzopyrene
79469
542756
57976
225514
193395
189559
3-11
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CHAPTER 4
OPTIONS FOR COMPLYING WITH THE CTG AND
OPTIONS FOR COMPLYING WITH THE NESHAP
Both the CTG and NESHAP include four options that a facility can use to comply
with the regulations. Table 4-1 summarizes these options. Each of these options has
advantages and disadvantages. In general, the more flexibility the option provides the
facility, the greater the recordkeeping requirements associated with the option.
TABLE 4-1. COMPLIANCE METHODS FOR THE CTG AND NESHAP
Compliance method
Compliant coatings
Averaging
Add-on control device
Combination
CTG
Yes
Yes, but may be limited by State
Yes
Yes
NESHAP
Yes
Yes, finishing only
Yes
Yes
While the compliance options are similar for the CTG and NESHAP, each option has
somewhat different requirements. In this chapter, we will discuss each of the options for the
CTG and the NESHAP and present example calculations that a facility can use to
demonstrate they are complying with each option. A detailed discussion of the recordkeeping
and reporting requirements associated with each option is presented in Chapter 5.
4.1 CTG COMPLIANCE OPTIONS
4.1.1 Compliant Coatings
The reference control technologies and corresponding emission limits for facilities
choosing to use a compliant coatings approach to meet the requirements of the CTG are
summarized in Table 2-2. As shown in the table, facilities can choose to use topcoats with a
VOC content no greater than 0.8 Ib VOC/lb solids, as applied, or sealers with a VOC
content no greater than 1.9 Ib VOC/lb solids, as applied, and topcoats with a VOC content of
no greater than 1.8 Ib VOC/lb solids, as applied. Less restrictive emission limits apply for
4-1
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facilities using acid-cured alkyd amino vinyl sealers and/or acid-cured alkyd amino
conversion varnishes.
For facilities using compliant coatings only, demonstrating compliance is
straightforward and relatively simple. First, the facility must maintain a certified product
data sheet (CPDS) for each coating subject to the emission limit. (A certified product data-
sheet is documentation furnished by the coating supplier or an outside laboratory that
provides the VOC content, VHAP content, solids content, and density of a coating or
solvent.) For example, if a facility chooses to comply using higher solids sealers and
topcoats, they must maintain a CPDS for each sealer and topcoat being used by the facility.
If the facility uses the coating as it is supplied, that is,- if they do not add any thinner or other
solvent to the coating, then the CPDS will be all the facility needs to demonstrate
compliance.
However, most facilities add thinner or other solvent to the coatings they purchase , ;=,
before they are applied. A facility may add thinner to adjust the viscosity or the color of the
coating or to slow down or speed up drying of the coating. Because the emission limits
presented in Table 2-2 are based on the VOC content of the coating as it is applied, the
facility must account for the addition of the thinner. Example 1 demonstrates how to
calculate the VOC content of a coating after thinning.
Facilities that thin their coatings before using them must maintain copies of the CPDS
showing the' VOC content; solids content, and density of the coating as supplied. They must
also maintain data sheets showing the VOC content of the as-applied coating in order to
demonstrate compliance. While this imposes an additional burden on the facility, it is the
only way the permitting authority has of determining what the VOC content of the coating is
at the tune it is being used.
Setting up a system to determine the VOC content of coatings-as -they are applied can
be straightforward. Figure 4-1 presents an example data sheet that can be given to each
operator responsible for thinning coatings. The operator only has to enter die identification
for the coating, the amount of coating used, the identification and quantity of any catalysts or
other additives, and the identification and quantity of any solvent added to the coating. This
information can then be entered into a spreadsheet that will automatically calculate the VOC
4-2
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"Example 1 - Calculating the As-Applied VOC Content of a Coating
• Compliance Method - Higher solids sealery'and*topcoats ^ '
content of top coat - 1.5 Ib VOC/lb solids, as supplied
""Emission limit - 1.8 Ib VOC/lb solids, as applied
Coating density - 8.0 Ib/gal
^ Coating solids content - 0.4 (40 percent)
" Coating usage - 1,000 gal
Solids used = Density x Gals used x percent solids
= 8.0 x 1,000x0.4
= 3,200 Ib solids
VOC from as-supplied coating = 1.5 Ib VOC/lb solids x 3,200 Ib solids
= 4,800 Ib VOC
Thinner VOC content - 6.8 Ib/gal
Thinner usage - 60 gal
VOC from thinner 6.8 x 60 = 408 Ib VOC
VOC from thinner and as supplied coating 4,800 + 408 = 5,208 Ib
Solids from as-supplied coating (also equal to solids of as-applied coating
because thinner contains no solids) = 3,200 Ib
VOC content of as applied coating = 5,208 Ib VOC/3,200 Ib solids = 1.63 Ib
VOC/lb solids, as applied.
In this case, the as-applied coating is still compliant, that is, it has a VOC
content no greater than 1.8 Ib VOC/lb solids, as applied.
.content of the coating as applied. Figure 4-2 presents an example spreadsheet for calculating
the VOC content of a coating that has been thinned. In this case, the facility should maintain
copies of the data sheet filled out by the operator and backup copies of the spreadsheet in
order to demonstrate compliance.
Table 4-2 summarizes the compliance demonstration requirements for facilities using
a compliant coatings approach to comply with the CTG.
4-3
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Manufacturer
Coating
type
Coating
serial No.
Coating
quantity
Catalyst
serial No.
Catalyst
quantity
Solvent
serial No.
Solvent
quantity
Water
quantity
Total
volume
Operator's
Initials
Figure 4-1. Example data sheet for spray booth operators.
Manufacturer
Coating
type
Serial
No.
VOC content,
(Ib VOC/lb
solids) as
supplied
(A)
Density
(B)
Percent
solids, by
weight
(C)
Coaling
usage, gal'
(D)
Solids
used. Ib"
(E)
VOC from
coaling, Ib' '
(F)
Thinner
usage, gal*
(G)
Thinner
VOC. Ib/gal
(H)
VOC from
thinner, Ib'
(I)
VOC content.
Ob VOC/lb
solids) as applied
coating*
(J)
'From operator data sheet.
•Solids used = B x D x (C/100).
'VOC from as applied coating = A x E.
•VOC from thinner = G x H.
'VOC content of as applied coating = (I + F)/E.
Figure 4-2. Example spreadsheet for calculating as-applied VOC content of coatings.
-------
TABLE 4-2. COMPLIANCE DEMONSTRATION FOR FACILITIES USING
COMELJANXCOATJNGS
Coating usage scenario
Compliance demonstration requirements
Coatings are used as supplied, that
is, no additives or thinners are
added to coating.
1. Maintain copies of CPDS.
Coatings are thinned before
application
1. Maintain copies of CPDS; and
2. Maintain data sheets showing coating and
thinner usage and calculation of as applied
VOC content.
4.1.1.1 Compliant Coatines and Continuous Coaters. The CTG includes special
compliance provisions for facilities that are using a compliant coatings approach and are
applying those coatings using a continuous coater. Continuous coaters are coating application
systems that apply the coating onto furniture or furniture parts as they move along on a
conveyor. Coating that is not transferred to the part is recycled to the coating reservoir.
Facilities may choose between the following two options for demonstrating compliance.
1. Option 1 for demonstrating compliance is basically the same as it is for coatings
that are not applied with continuous coaters. Facilities must maintain copies of the CPDS for
each coating subject to an emission limit, and, if the coating is subsequently thinned, they
must maintain records that demonstrate the VOC content of the a^applied coating does not
exceed the emission limit for that coating. If an inspector takes a sample of the coating in
the reservoir and performs a Method 24 (40 CFR Part 60, Appendix A) analysis of the
sample, the coating must have a VOC content no greater than the emission limit for the
coating.
2. Under option 2, the facility must monitor the viscosity of the coating hi the
reservoir. The viscosity of the initial coating in the reservoir must be measured. The
facility may then either monitor the viscosity of the coating in the reservoir continuously with
a viscosity meter, or they may measure the viscosity each time solvent is added. If, at any
time, the viscosity of the coating in the reservoir is less'than-the viscosity of the initial-
4-5
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coating, the facility is out of compliance. The facility must also maintain a record of all
solvent and -coating additions ttvthe reservoir. As with option,!, if an inspector takes a
sample of the coating in the reservoir, the VOC content must not exceed the emission limit
for that coating. However, the VOC content as calculated from the facility's records may
exceed the emission limit.
4.1.2 Averaging
The CTG allows averaging to be used as a compliance option, and it provides detailed
guidance on how an averaging program works. However, as with all aspects of the CTG,
the State and/or local agency may choose to disallow this compliance option. Some States
have expressed concern about the additional burden an'averaging approach places on their
resources. Some have indicated they may allow averaging, but they may place restrictions
on it that are not included in the program presented in the CTG. For example, some States
may limit the type of coatings that may be included in an averaging program. Facilities that
wish to use an averaging program to comply with the CTG should first contact their State or
local agency to determine if the State is allowing an averaging approach and, if so, any
restrictions that may apply.
Facilities using an averaging approach to comply with the CTG may use one of two
equations to demonstrate they are in compliance. The equation the facility chooses to use
will depend upon the coatings they would like to average among. Sources that choose to use
an averaging approach-must demonstrate that emissions from finishing operations at the
source are no greater than the emissions that are allowed using either Equation 1 or 2.
+ TC2 + TC3 + ...)] >. (ERraCrQ) + ERTC2(TC2) + ERTC3(TC3) +
(Equation 1)
0.9K1.8CTC! + TC2 + ...)) + (1.9(SE, + SE, + ...» + (9.0(WC, + WC2
+ (1.2(BC, + BC2 + ...)) +(6.6(ST, + ST2 + ...))>_ (ER^CTC,) + ERTC
+ ...) + (ERsE.CSE,) + ERsaCSEj) + ...) + (ERWC1(WC,) + ERWC2(WC2)
(ERBC1(BC,) + ERBC2(BC2) + ...) + (ER^ST,) + ERST2(ST2) + ...)
(Equation 2)
where:
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= pounds of solids of topcoat "i" used;
= pounds of solids of sealer Tj" used;
j = pounds of solids of washcoat "i" used;
j = pounds of solids of basecoat "i" used;
= gallons of stain "i" used;
ERTCl = VOC content of topcoat "i" in Ib VOC/lb solids, as applied;
ERjjEj = VOC content of sealer "i" in Ib VOC/lb solids, as applied;
ERWCi = VOC content of washcoat "i" in Ib VOC/lb solids, as applied;
ERBCi = VOC content of basecoat "i" in Ib VOC/lb solids, as applied;
ERsjj = VOC content of stain "i" in Ib VOC/gal, as applied.
In both equations (1) and (2) the facility must use the actual VOC content of the
coatings that were in use before they were subject to RACT if the VOC content of those
Coatings is less than the allowed VOC content. For example, if you were using topcoats that
had a VOC content of 1.7 Ib VOC/lb solids before you were subject to RACT, you would
have to use 1.7, rather than 1.8, as the multiplier for the topcoat in Equation (2).
The equation a facility chooses to use will be based on the type of low-VOC finishing
system that it is using. If a facility has reformulated many of its topcoats so that they have a
§/OC content lower than 0.8, but there are some topcoats that the facility needs to use for
other applications that have a VOC content greater than 0.8, then, the facility would use
Equation (1). This would allow the facility, to^continue using .the jopcoats with a higher
VOC content than the emission limit for topcoats. Example 2 illustrates a facility that may
want to average among their topcoats and how they would determine they were in
compliance using Equation (1).
Some facilities have invested time and money in developing reverse hybrid finishing
•-systems in which the stains and, in some cases, the washcoats are waterborne coatings, but
the sealers and topcoats are traditional nitrocellulose coatings. Because the reference control
technologies for the CTG are based on lower-VOC topcoats and sealers, these facilities will
either have to reformulate their sealers and topcoats also or they will need to comply using
an averaging approach. Facilities that have reformulated their color coats rather than their
topcoats can use Equation (2) to demonstrate compliance. Example 3 illustrates the
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.Example ^ - Averaging.Topcoats Only for the CTG
Facility Description - Manufacturer of business furniture with two finishing
lines. One line is a flatline operation for finishing components of furniture that are
assembled after finishing. Coatings are applied using a roll coaler. One line is a spray
finishing operation for furniture that is assembled and then finished. The facility is
using a UV-cured topcoat on the flatline finishing system and an acid-catalyzed topcoat
on the spray line. Table 4-3 presents the VOC and solids content and usage for each
of the coatings.
TABLE 4-3. COATING PARAMETERS FOR FACILITY AVERAGING TOPCOATS
Coating parameters
VOC content, Ib VOC/lb solids
Density, Ib/gal
Solids content, percent by weight
Usage, gal/d
Usage, Ib solids/d
UV-cured topcoat
0.1
9.8
90
150
1,323
Acid-catalyzed topcoat
2.3
7.6
30
90
205
The facility's allowable emissions are equal to:
0.9(0.8(1,323 + 205)) = 1,100 Ib VOC/day
The facility's actual emissions are equal to:
(0.1)(l,-323) + <2:3)(205) = 604 Ib VOC/day
Because the facility's actual emissions for the day are less than their allowable
emissions they are in compliance with the standard even though one of their topcoats
has a VOC content greater than the emission limit of 0.8.
averaging procedure for a facility using a reverse hybrid system.
The facility in Example 3 is likely using other coatings in their finishing sequence,
but the CTG limits the coatings that can be averaged to those shown in the equation. For
example, fillers and highlights cannot be used in the averaging equation. However, the
facility does not have to be using all of the coatings listed in Equation (2) to participate hi
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Example 3 - Averaging for a Facility Using a Reverse Hybrid Finishing System
Facility Description - Manufacturer x>f medium to high end furniture that has
determined that a reverse hybrid system allows them to achieve the overall appearance
they are trying for better than a traditional hybrid system where the sealers and
topcoats are reformulated. The facility is using waterbome stains and washcoats and
conventional nitrocellulose sealers and topcoats. Table 4-4 presents the coating
parameters and usage.
TABLE 4-4. COATING PARAMETERS AND USAGE FOR FACILITY USING
REVERSE HYBRID FINISHING SYSTEM
Coating
Waterbome stain (includes toner)
Waterborne washcoat
Sealer
Topcoat
VOC'
0.8
0.9
3.9
3.4
Density,
Ib/gal
8.4
8.5
7.4-
7.6
% solids
0.6
8.5
20
23
Usage"
308
50
270
728
'For stains, the VOC content is in units of Ib VOC/gal. For other coatings, the VOC content is Ib
VOC/lb solids. All values are as applied.
bFor stains, usage is in gallons per day. For other coatings, usage is pounds of solids per day.
Using the above coating parameters and usage ratio, the facility's allowable
emissions are equal to:
0.9*[(1.8)(728) + (1.9)(270) + (9.0)(50) + (6.6)(308)J = 3,876 Ib
The facility's actual emissions are:
(3.4)(728) + (3.9)(270) + (0.9)(50) + (0.8)(308) = 3,820
The facility's actual emissions are slightly lower than the allowable emissions as
calculated using Equation (2), so the facility is in compliance with the emission limits.
averaging. For example, in Example 3, the facility is not using basecoats so they are not
included in the calculation.
Facilities using an averaging approach must maintain the following records to
demonstrate compliance:
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- Certified product data sheets for coatings participating in averaging;
- Data sheets showing VOC content of coating as applied; and
- Records of the amount of each coating used.
4.1.3 Add-on Control Devices
The CTG also provides the facility the option of complying with the coating VOC
emission limits through the use of an add-on control device. It is anticipated that only a few
facilities will choose this option, but it is available. Currently, add-on control devices are
being used by only a few facilities, and those are primarily large kitchen cabinet and business
furniture manufacturers with automated flatline finishing systems. Controlling traditional
wood furniture manufacturing exhaust streams, which "are typically high volume, low
concentration streams, with add-on control devices is technically feasible but not very cost
effective.
The CTG provides guidance on how to demonstrate compliance when usiag thermakx
oxidizers, catalytic oxidizers, and carbon adsorbers, but a facility may choose to use another
type of control device. Facilities using other types of control devices should work with EPA
and the State to develop compliance demonstration requirements for those control devices.
The CTG also recognizes that the overall control efficiency of a control system is a
product of the destruction/removal efficiency of the control device and the capture efficiency.
The capture efficiency is the ratio of the quantity of pollutants entering the control device to
rne"quantity tJfpoHntant5*«rnitted from the emission source. The CTG model rule and the
NESHAP identify the methods to be used to determine the capture efficiency initially.
Because these methods are somewhat complicated and apply to only a few facilities, they will
not be discussed in detail here. Facilities using an add-on control device should review the
appropriate sections of the model rule to find out more about these methods.
Facilities using add-on control devices must conduct a performance test to
demonstrate the overall control efficiency of the system. During the performance test, they
need to establish operating parameter(s) they can monitor that will demonstrate that the
control device is continually achieving the required control efficiency. If they cannot
establish an operating parameter, they may have to continually monitor VOC emissions at the
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inlet and outlet of the control device. Table 4-5 presents operating parameters to be
monitored for facilities using thermal oxiddzers, catalyii&oxidizersrand carbon adsorbers,.
TABLE 4-5. OPERATING PARAMETERS FOR ADD-ON CONTROL DEVICES
Control device
Thermal oxidizer
Catalytic oxidizer with fixed catalyst
bed
Catalytic oxidizer with fluidized
catalyst bed
Carbon adsorber
Operating parameter(s)
Minimum combustion temperature
Minimum gas temperature upstream and
downstream of the catalyst bed
1 . Minimum gas temperature upstream of the catalyst bed;
and
2. Pressure drop across the catalyst bed.
1 . Total regeneration mass stream for each regeneration
cycle; and
2. Carbon bed temperature after each regeneration.
To demonstrate continuous compliance with the standard using a control device, the
facility must continuously monitor the operating parameter(s) to demonstrate that the
operating parameter(s) are in the range established during the initial performance test.
4.1.4 Combination of Compliance Options
The CTG allows facilities to use any combination of the three options to comply with
the standard. Facilities using a combination of compliance methods will have to follow the
compliance demonstration requirements for each of the individual compliance methods. For
example, a facility may have their emissions from one finishing line directed to an add-on
control device, but they may be using compliant coatings on the other finishing line. The
facility would have to maintain the records required for demonstrating their coatings are
compliant, and they would have to monitor the selected operating parameters of the control
device to demonstrate they are achieving the required control efficiency.
4.2 NESHAP COMPLIANCE OPTIONS
The NESHAP also provides three primary options for complying with the emission
limits for finishing operations. There are two methods that facilities can use to comply with
the emission limits for contact adhesives.
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4.2.1 Compliance Options for Finishing Operations
4.2.1.1 Compliant Coatings. Table 2-4 presents the NESHAB emission limits for
coatings for both existing and new sources. ..As shown in the table, the standard limits the
VHAP content of all stains, washcoats, sealers, topcoats, basecoats, enamels, and thinners
used by a facility. There is no limit on the VHAP content of coatings typically used in
smaller amounts, such as fillers and glazes. With the exception of the emission limit for
stains, the emission limits for coatings used by new sources are more stringent than those
used by existing sources.
To demonstrate compliance with the NESHAP emission limits for coatings, facilities
have to maintain copies of certified product data sheets for each coating, and thinners added
to those coatings, subject to an emission limit. If a facility thins the coatings before
application, the NESHAP does not require the facility to maintain data sheets showing the
amount of thinner added to each batch and the VHAP content -of that batcfcafter thinning,.. ,/
However, the emission limits are on an as applied basis so facilities do need to make sure
that they are not thinning the coating to the point that the emission limit is exceeded. If an
inspector comes in and takes a sample of the coating-and it exceeds the limit, the facility will
be in violation of the standard even though the CPDS shows the VHAP content of the
coating is no greater than the emission limit established for that coating and the thinner the
facility used had a VHAP content less than 10.0 percent by weight. Therefore, it is probably
in the best interest of the facility to maintain data sheets for calculating the as-applied VHAP
content even though it is not required by the NESHAP.
In summary, facilities using a compliant coatings approach to comply with the
NESHAP limits for finishing operations are only required to maintain certified product data
sheets for each coating subject to an emission limit and any thinners that are added to those
coatings.
4.2.1.1.1 Compliant coatings and continuous coaters. As with the CTG, the
NESHAP contains special compliance provisions for facilities that are using a compliant
coatings approach to comply with the coating emission limits and are applying those coatings
with a continuous coater. Facilities may choose between the same two options that are
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presented in 4.1.1.1 for the CTG. The only difference is that the NESHAP limits the VHAP
content of the coating, rather than the VOC content.
4.2.1.2 Averaging. The NESHAP also provides facilities the option of averaging
their coatings to meet the standard. Whereas the CTG requires facilities to meet a daily
average, the NESHAP gives facilities the flexibility of meeting a monthly average. For
existing sources, the average VHAP content for all finishing materials used at the facility
during the month must be no greater than 1.0 Ib VHAP/lb solids, as applied. For new
sources, the limit is 0.8 Ib VHAP/lb solids, as applied. Note that although the compliant
coatings approach only requires specific coatings to meet the emission limits, all coatings
used at the facility during the month must be included in the averaging equation for the
NESHAP.
Both existing and new sources must use the following equation to demonstrate
compliance when using an averaging approach:
E = (MelCel + M*Ca + ... + McnCcn + S,W, + S2W2 + ...
SnWJ/CM,, + M^ + ... + Mcn)
Equation (3) -
where:
E = average VHAP content of finishing materials (Ib VHAP/lb solids);
Mcn = the mass of solids in finishing material (c) used monthly (Ib solids/month);
Ccn = the VHAP content of finishing material (c) in Ib VHAP/lb solids;
Sn = the VHAP content, expressed as a weight fraction, of any thinners added to the
finishing materials participating in the averaging equation; and
Wn = the amount of Sn, in pounds, added to the finishing materials during the
monthly averaging period.
For existing sources, E must be no greater than 1.0 Ib VHAP/lb solids. For new sources, E
must be no greater than 0.8.
To demonstrate compliance using an averaging approach, a facility must:
1. Maintain certified product data sheets for each finishing material;
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2. Maintain records of the amount of each finishing material used each month and
the'^prfcent solids" of that finishing materials order to determine 'the ^pounds of solids of each
finishing material used;
3. Maintain certified product data sheets for all thinners added to the finishing.
materials used each month; and
4. Maintain records of the amount of thinners, in pounds, added to the finishing
materials during the month.
Example 4 illustrates a facility that has chosen to use an averaging approach to meet
the NESHAP emission limits for finishing operations.
4.2.1.3 Add-On Controls. Facilities may also'use an add-on control device to meet
the NESHAP emission limits for finishing operations. As discussed earlier, however, it is
anticipated that few facilities will choose to use add-on controls due to the high capital and
operating costs that would be incurred. The compliance demonstration requirements for
facilities using add-on control devices to meet the NESHAP emission limits are the same as
those for the CTG, which are discussed in 4.1.3. The reader should refer to that discussion
to review those requirements.
4.2.1.4 Combination of Compliance Options. The NESHAP allows facilities to use
any combination of the three options to meet the emission limits for finishing operations. If
using a combination of options, the facility must meet the compliance demonstration
requirements associated -with each option.
4.2.2 Compliance Options for Gluing Operations
As discussed in Chapter 2, the NESHAP also establishes emission limits for contact
adhesives. Facilities using contact adhesives have two options for demonstrating
compliance—using compliant contact adhesives, that is, those that meet the emission limits
presented in Table 2-4, or using an add-on control device.
4.2.2.1 Compliant Contact Adhesives. Table 2-4 presents the emission limits for
contact adhesives for both existing and new sources. There are two categories of contact
adhesives for the purposes of this rule: foam adhesives and all other contact adhesives
(excluding aerosol adhesives and excluding contact adhesives used on nonporous substrates
such as metal, rubber, rigid plastic, or flexible vinyl). For existing sources, the limit is less
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.Example 4 - Calculations to Demonstrate Compliance for a Facility Using an
**
Averaging Approach to Meet the NESHAP Emission Limits
Facility Description - The facility is a medium sized
about 60,000 gallons of coating
per year, with
sealer, and topcoat. The facility is an existing
kitchen cabinet plant using
a basic finishing sequence
of stain,
source, so they must achieve an average
emission limit of no more than 1.0 Ib VHAP/lb solids, as applied. In order to meet
the NESHAP emission limits, they have decided to use sealers and topcoats with
slightly higher solids contents, that is, about 35 percent. They have also worked with
their coating supplier to try and
lower the HAP content of these coatings by using as
much as possible non-HAP solvents. The facility has had little success reformulating
their stains, however, so they must use an averaging approach to meet the standard.
The facility also uses small amounts of thinner
sealers and topcoats. Table 4-6
facility.
, typically lacquer thinner,
for their
presents the coating usage and parameters for the
TABLE 4-6. COATING PARAMETERS FOR FACILITY USING AVERAGING
APPROACH TO MEET THE NESHAP EMISSION LIMITS FOR FINISHING
Parameters
Usage (gal/month)
Density Ob/gal)
% Solids (by weight)
Usage (Ib solids/month)
VHAP content (Ib/gal)
VHAP content (Ib VHAP/lb solids)
Using Table 4-6:
Stain
925
6.7
1.5
93
0.1
45
Sealer
2,000
7.8
35
5,460
2.0
0.7
Topcoat
2,075
7.9
35
5,737
1.5
0.5
Thinner
60
6.8
0
0
3.4
N/A
E = ((93)(45) + (5,460)(0.7) + (5,737)(0.5) + (60)(6.8)(0.5))/(93 + 5,460 + 5,737) = 0.98 Ib VHAP/lb solids
Because E is less than 1 .0 the
source, it would not be in compliance.
facility is in compliance. However, if this facility were a new
stringent for foam adhesives due to problems encountered in formulating foam adhesives that
pass flammability tests. The compliance demonstration requirements for facilities using.
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compliant contact adhesives are the same as those for facilities using compliant coatings to
meetthe finishing limits.
If a facility does not thin their contact adhesives onsite, the only requirement for
demonstrating compliance is to maintain a certified product data sheet for each contact
adhesive. However, if the facility thins their adhesives onsite, they must also maintain data
sheets that demonstrate the as-applied VHAP content of the-contact adhesive does not exceed
the allowable level. Because the limit for contact adhesives varies according to the use of the
adhesive, the facility should also maintain a record of how the contact adhesive was used.
Table 4-7 summarizes the compliance demonstration requirements for facilities using contact
adhesives.
TABLE 4-7. COMPLIANCE DEMONSTRATION FOR COMPLIANT
CONTACT ADHESIVES
Adhesive usage scenario
Compliance demonstration requirements
Contact adhesives are used as supplied,
that is, no additives or thinners are
added to the contact adhesive.
1. Maintain copies of certified product data
sheets; and
2. Maintain record of operation for which
contact adhesive was used.
Contact adhesives are thinned before
application
1. Maintain copies of certified product data
sheets;
2. Maintain data sheets showing contact
adhesive and thinner usage and calculation
of as-applied VHAP content; and
3. Maintain record of operation for which
adhesive was used.
4.2.2.2 Add-On Control Devices. The compliance demonstration requirements for
facilities using an add-on control device to reduce emissions from the use of contact
adhesives are the same as those discussed in 4.1.3 for facilities using a control device to
meet the emission limits for finishing operations.
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CHAPTER 5
RECORDKEEPING AND'TIEPORTING^REQUIREMENTS
This section presents the recordkeeping and reporting requirements for facilities
subject to the CTG and/or NESHAP. In general, these requirements will vary according to
the method the facility chooses to use to demonstrate compliance.
5'l RECORDKEEPING REQUIREMENTS
Because many facilities are expected to use a compliant coatings and/or contact
adhesives approach to meet the requirements of the CTG and NESHAP, maintaining
complete records is particularly important because they allow these facilities to demonstrate
compliance. Therefore, many of the recordkeeping requirements discussed in this chapter
were also discussed in Chapter 4. However, in addition to the recordkeeping requirements
associated with the emission limits and compliance options presented in Chapters 2 and 4,
this chapter will also discuss recordkeeping requirements associated with the work practice
standards. Because most of the work practice standards are included in both the CTG and
NESHAP, the recordkeeping requirements associated with them will be addressed hi a
separate section to avoid repeating them in the discussion for both the CTG and the
NESHAP.
Both the CTG and the NESHAP require facilities to maintain all records for 5 years.
5.1.1 CTG Requirements
Table 5-1 summarizes the recordkeeping requirements associated with each of the
compliance options presented in Chapter 4.
Facilities should note that the recordkeeping requirements listed in the table for
facilities using an averaging approach represent the minimum requirements. If an individual
State chooses to allow averaging, they may have more stringent recordkeeping requirements.
5.1.2 NESHAP Recordkeeping Requirements
As with the CTG, the recordkeeping requirements for the NESHAP are dependent
upon the option the facility is using to demonstrate compliance. Table 5-2 summarizes the
recordkeeping requirements by compliance'option for both finishing and gluing operations.
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TABLE 5-1. RECORDKEEPING REQUIREMENTS FOR THE CTG
Compliance option
Recordkeeping requirements
Compliant coatings
1. Certified product data sheets for each coating
subject to the emission limits presented in
Chapter 2; and
2. If coatings are thinned, data sheets showing
coating and thinner usage and calculation of the
as applied VOC content.
Compliant coatings with
continuous coaters
Option 1
- Same as for compliant coatings. Records must
. demonstrate that the as-applied VOC content
does not exceed the applicable emission limit.
Option 2
1. Certified product data sheet for the as-supplied
coating;
2. Record of all solvent and finishing material
additions to the reservoir; and
3. All viscosity measurements.
Averaging
Certified product data sheets for each coating
participating in averaging;
Data sheets showing coating and thinner usage
and calculation of the as-applied VOC content;
Records of the amount of coating used per day;
and
Copies of the averaging calculation.
Add-on control
1. Certified product data sheets for each coating;
2. Copies of calculations demonstrating the
equivalency of using a control system;
3. Records of the daily average value of each
continuously monitored parameter; and
4. For facilities using a fluidized bed catalytic
incinerator, records of the pressure drop across
the catalyst bed.
Combination of options
All records required by each of the options.
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TABLE 5-2. RECORDKEEPING REQUIREMENTS FOR THE NESHAP
Compliance option
I Recordkeeping requirements «•&*j
Finishing operations
Compliant coatings
1. Certified product data sheets for each coating and thinner
subject to the emission limits presented in Chapter 2; and
2. The VHAP content, in Ib VHAPAb solids, as applied, for
each coating subject to the emission limits presented in
Chapter 2.
Compliant coatings with continuous
coaters
Option 1
• Same as requirements for compliant coatings. Records
must demonstrate that the VHAP content does not exceed
the applicable emission limit.
Option 2
1.. Certified product data sheet for each coating and thinner;
2. Record of all solvent and coating additions to the reservoir;
and
3. All viscosity measurements.
Averaging
1. Certified product data sheets for each coating participating
in averaging;
2. Records of the amount of coating and thinner used each
month;
3. Copies of the averaging calculation.
Add-on control device
1. Certified product data sheets for each coating;
2. Copies of calculations demonstrating equivalency of using a
control system;
3. Records of the daily average value of each continuously
monitored parameter; and
4. For facilities using a fluidized bed catalytic incinerator,
records of the pressure drop across the catalyst bed.
Compliant coatings and control device
or averaging and control device
Maintain all records required by each individual option.
Gluing Operations
Compliant contact adhesives
Certified product data sheet for each contact adhesive
subject to the emission limits presented in Chapter 2;
If adhesives are thinned, data sheets showing contact
adhesive and thinner usage and calculation of the as applied
VHAP content; and
Records documenting the process in which the contact
adhesive was used.
Add-on control device
Certified product data sheet for each contact adhesive
subject to the emission limits presented in Chapter 2;
Copies of calculations demonstrating the equivalency of
using a control system;
Records of the daily average value of each continuously
monitored parameter; and
For facilities using a fluidized bed catalytic incinerator,
records of the pressure drop across the catalyst bed.
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Note that the recordkeeping requirements for the NESHAP are very similar to those for the
Cf-G.^Ttos'should help -minimize ^-recordkeeping iurden. for facilities that are subject to. .7.
both.
5.1.3 Recordkeeoing Requirements for Work Practice Standards
Most of the work practice standards are included in the CTG and the NESHAP. The
two exceptions are the formulation assessment plan for finishing operations and the limitation
on the chemical composition of cleaning and washoff solvents, which are included in the -
NESHAP but not the CTG. Section 5.1.3.1 summarizes the recordkeeping requirements for
the work practice standards that are common to both the CTG and NESHAP, and
Section 5.1.3.2 summarizes the recordkeeping requirements associated with the formulation
assessment plan and the limitation on the chemical composition of cleaning and washoff
solvents.
5.1:3.1 CTG and NESHAP Work Practice Standards. Because the work practice
standards are considered a critical element of both the CTG and NESHAP, EPA has included
recordkeeping requirements to ensure facilities are implementing these standards. A
summary of the recordkeeping requirements associated with the work practice standards that
are common to both the CTG and NESHAP is included in Table 5-3.
Facilities are also required to maintain a copy of the work practice implementation
plan onsite. The work practice implementation plan should include a copy of the operator
training program,^the inspection and maintenance plan, the cleaning and washoff solvent
accounting system, and for facilities subject to the NESHAP, the formulation assessment plan
for finishing operations.
The work practice standards also include requirements for storing materials and for
spray gun and line cleaning. One option to ensure these standards are being met is to
develop a checklist that a designated employee or supervisor can-use ta«nsure that these
work practice standards are being followed. If operators know that plant personnel are
performing regular checks, they are more likely to follow the appropriate procedures. An
example work practice inspection checklist is included in Chapter 8.
5.1.3.2 Work Practice Standards for the NESHAP Only. As discussed in Chapter 3,
the NESHAP includes two work practice standards that are not included in the CTG. These
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TABLE 5-3. RECORDKEEPING REQUIREMENTS FOR THE CTG AND NESHAP
WORK PRACTICE STANDARDS
Work practice standard
Recordkeeping requirements
Operator training program
1. Copy of program, including:
- a list of personnel required to be trained;
- an outline of the subjects to be covered; and
- lesson plans for training courses;
2. Records documenting successful completion of
the training program for each individual; and
3. Date each individual was trained.
Inspection and maintenance plan
1. Copies of checklists documenting visual
monthly inspection of equipment; and
2. Records demonstrating timeframe for making
repairs.
Cleaning and washoff solvent
accounting system
1. Record of the quantity and type of organic
solvent used each month for washoff and
cleaning;
2. Record of the number of pieces washed off
and the reason why; and
3. Record of the quantity of spent solvent
generated each month by operation and
whether it is recycled onsite or disposed
offsite.
Spray booth cleaning
VOC content of material used for cleaning spray
booths.
Application equipment requirements
Documentation that conventional air spray guns
are only being used as allowed, including:
if used for applying low-VOC coatings,
records showing that the VOC content is
no greater than 1.0 Ib VOC/lb solids;
if used for applying small quantities of
finishing materials, other than for
touchup and repair, records of total
finishing material usage and quantity
applied with air spray gun.
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include the formulation assessment plan for finishing operations and the limitation on the
chemical composition ofocleaaing andiwashoff solvents. c.Both of these-work practice
standards have recordkeeping requirements associated with them. Table 5-4 summarizes the.
recordkeeping requirements associated with these two work practice standards.
TABLE 5-4. ADDITIONAL RECORDKEEPING REQUIREMENTS FOR
NESHAP WORK PRACTICE STANDARDS
Work practice standard
Formulation assessment plan for
finishing operations
Limitation on chemical
composition of cleaning/washoff
solvents
Recordkeeping requirements
1. Maintain MSDS for coatings containing VHAP of
potential concern; and
2. Maintain usage records for coatings containing
. VHAP of potential concern.
Maintain MSDS for all solvents used for cleaning
and/or washoff.
5.2 REPORTING REQUIREMENTS
As with the recordkeeping requirements, many of the reporting requirements are the
same for the CTG and the NESHAP. They are also consistent with reporting requirements
associated with the Title V Operating Permit Program, which are discussed hi Chapter 7.
The goal hi making the reporting requirements consistent was to minimize the burden on
facilities that are subject to the CTG and NESHAP and will be required to obtain a Title V
permit.
The reporting requirements for the CTG and NESHAP are discussed separately here
because some facilities will not be subject to both. However, facilities subject to both the
CTG and NESHAP can include all the required information in one report.
5.2.1 CTG Reporting Requirements
There are two main reporting requirements associated with the CTG: an initial
compliance status report and a semiannual continuous compliance report. Table 5-5
summarizes the information that should be included in the initial compliance report.
Facilities are required to submit the initial compliance report within 60 days of the
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TABLE 5-5. INFORMATION INCLUDED IN INITIAL COMPLIANCE
REPORT FOR CTG
Compliance method
Information included in report
Compliant coatings
Statement that the facility is using compliant sealers
and/or topcoats and strippable booth coatings.
Compliant coatings with
continuous coaters
1. Statement that the facility is using compliant
sealers and/or topcoats, as determined by the
VOC content of the coating hi the reservoir and
the VOC content calculated from records; or
2. Statement that the facility is using compliant
sealers and/or,topcoats, as determined by the
VOC content of the coating in the reservoir, and
the facility is monitoring the viscosity of the
coating in the reservoir; and
3. Data demonstrating the correlation between the
VOC content of the coating in the reservoir and
the viscosity of the coating.
Averaging
The CTG does not designate specific information
that must be included in the initial compliance status
report. A facility using an averaging approach
should work with their permitting authority to
determine what information should be included.
Add-on controls
1. Monitoring plan that identifies each operating
parameter to be monitored for the control device;
and
2. Results of the initial performance test.
Compliance with work practice
standards
Statement that the work practice implementation plan
has been developed and the facility has established
procedures for implementing the provisions of the
plan.
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compliance date, which, for the CTG, will vary between States.
Table 5-6 summarizes the information, that- should-be. included Jn the semiannual
compliance status reports for the CTG. The first semiannual report, which should cover the
previous 6 months of wood furniture manufacturing operations, must.be submitted within.30
calendar days of the end of the first 6-month period following the compliance date.
Subsequent reports must be submitted within 30 calendar days of the end of the previous
6-month reporting period.
The semiannual compliance status report must be signed by a responsible official of
the company that owns or operates the facility. A responsible official can be any of the
following:
- The president, vice-president, "secretary, or treasurer of the company that owns the
plant;
- The owner of the plant;
- The plant engineer or supervisor;
- A government official if the plant is owned by the Federal, State, City, or County
government; or
- A ranking military officer if the plant is located on a military base.
5.2.2 NESHAP Reporting Requirements
The reporting requirements for the NESHAP are essentially the same as those for the
CTG. The facility-must submit an initial notification no later than 270 days after
promulgation of the rule. The initial notification report gives the permitting authority an idea
of how many facilities will be subject to the NESHAP. The facility must also submit an
initial compliance status report and semiannual continuous compliance status reports.
Table 5-7 summarizes the information that should be included in the initial compliance
report. The initial compliance report must be submitted no later than 60 days after the
compliance date. Appendix G contains example initial notification and initial compliance
report forms.
The first semiannual compliance status report must be submitted no later than
30 calendar days after the end of the first 6-month period following the facility's compliance
date. Subsequent reports must be submitted no later than 30 calendar days after the end of
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TABLE 5-6. INFORMATION TO BE INCLUDED IN SEMIANNUAL
COMPLIANCE STATUS REPORTS EOR THE CTG
Compliance method
Information to be included in report
Compliant coatings
Statement that compliant sealers and/or topcoats and
strippable booth coatings have been used each day in the
reporting period. If noncompliant coatings have been
used, the report should identify the days of
noncompliance and the reasons.
Compliant coatings with continuous
coalers
1. Statement that compliant sealers and/or topcoats, as
determined by the VOC content of the coating in the
reservoir and the VOC content as calculated from
records, have been used each day in the semiannual
period. If noncompliant coatings have been used, the
. report should identify the days of noncompliance and
the reasons; or
2. Statement that compliant sealers and/or topcoats, as
determined by the VOC content of the coating in the
reservoir, have been used each day in the reporting
period, and the viscosity of the coating in the
reservoir has not been less than the viscosity of the
initial coating. If noncompliant coatings have been
used or the viscosity of the coating in the reservoir
has exceeded the viscosity of the initial coating, the
report should identify the days of noncompliance and
the reasons why.
Averaging
The CTG does not designate specific information that
should be included in the compliance status report. The
facility should work with their permitting authority to
identify information to be included in the report.
Add-on control device
Statement that the facility has not operated the capture or
control device at a daily average value greater than or
less than (as appropriate) the operating parameter value.
Compliance with work practice
standards
Statement that the work practice implementation plan is
being followed, or, if any provisions of the plan have not
been followed during the reporting period, a description
of the violation and the time period during which it
occurred.
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TABLE 5-7. INFORMATION TO BE INCLUDED IN INITIAL COMPLIANCE
REPORT POR THE NESHAP
Compliance method
Information to be included in report
Compliant coatings/contact
adhesives
Statement that the facility is using compliant
coatings, thinners, and/or contact adhesives.
Compliant coatings with
continuous coaters
1. Statement that the facility is using compliant
coatings, as determined by the VHAP content of
the coating in the reservoir and the VHAP
content as calculated from records, and compliant
thinners; or
2. Statement that the facility is using compliant
coatings, as determined by the VHAP content of
• the coating in the reservoir, and compliant
thinners and that they are monitoring the viscosity
of the coating in the reservoir; and
3. Data demonstrating relationship between the
viscosity of the coating in the reservoir and the
VHAP content of the coating.
Averaging (coatings only)
Results of averaging calculation for the first month,
starting the first day of the month following the
compliance date.
Add-on control device
1. Monitoring plan that identifies each operating
parameter to be monitored for the capture device;
and
2. Results from initial performance test.
Compliance with work practice
standards
Statement that the facility has developed a work
practice implementation plan and has established
procedures for implementing the provisions of the
plan.
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TABLE 5-8. INFORMATION TO BE INCLUDED IN THE SEMIANNUAL
COMPLIANCE STATUS REPORT FOR.THE NESHAP
Compliance with emission limits
for coatings/contact adhesives
Information to be included in report
Compliant coatings and/or
contact adhesives
Statement that the facility has used compliant
coatings, thinners, and/or contact adhesives each day
during the reporting period. If noncompliant
coatings, thinners, or contact adhesives have been
used during the reporting period, the facility should
identify when the coatings/thinners/adhesives were
used and the reasons why.
Compliant coatings with
continuous coaters
1. Statement that the facility has used compliant
coatings, as determined by the VHAP content of
the coating in the reservoir and the VHAP
content of the coating as calculated from records,
and compliant thinners each day during the
reporting period; or
2. Statement that the facility has used compliant
coatings, as determined by the VHAP content of
the coating in the reservoir, and compliant
thinners each day in the reporting period and that
the viscosity of the coating in the reservoir has
not been less than the viscosity of the initial
coating.
Averaging (coatings only)
Results of the averaging equation for each month
within that semiannual period.
Add-on control device
Statement that the facility has not operated the
capture or control device at a daily average value
greater than or less than (as appropriate) each
operating parameter value.
Compliance with work practice
standards
Statement that the work practice implementation plan
is being followed, or, if any provisions of the plan
have not been followed during the reporting period,
a description of the violation and the time period
during which it occurred.
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each 6-month period. Table 5-8 summarizes the information to be included in the status
-senriatmual compliance status reports for the NESHAP.
As with the semiannual continuous compliance status report required by the CTG, the
NESHAP status report must be signed by a responsible official of the company that owns or
operates the facility. Appendix G contains an example semiannual continuous compliance
status report form. Also, please refer to Table 1 of the NESHAP (see Appendix F) for the
reporting requirements of the General Provisions (40 CFR 63, Subpart A).
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CHAPTER 6
AVAILABLE CONTROL TECHNOLOGIES
This section presents an overview of control technologies that can be used by wood
furniture manufacturing facilities to meet the requirements of the CTG and/or NESHAP.
Because of the variety of products manufactured by the wood furniture industry and the
range of performance and appearance requirements for those products, there is no one
control technology that can be used by all facilities to reduce emissions. The "best" control
technology for a kitchen cabinet plant is probably not the "best" control technology for a
plant manufacturing higher end residential furniture. It may not even be the best control
technology for another kitchen cabinet plant. However, both the CJG and NESHAP
recognize the diversity of the industry. They do not mandate the use of a particular control
£-•
technology. Instead, the CTG and NESHAP allow facilities to choose the option best suited
to" their operations as long as they can demonstrate they are achieving a level of control
equivalent to that required by the standards.
There are two basic options that facilities can use to meet the requirements of the
CTG and/or NESHAP. These options include reformulating some or all of their coatings so
«
that they contain less VOC and/or HAP or using an add-on control device to reduce
emissions. Because typical wood furniture emission streams are low concentration, high
volume streams, add-on control devices have been used only in a'lrniited number of cases in
the wood furniture industry. While a brief discussion of add-on control devices is included
in this chapter, the focus will be on reformulated coatings.
6.1 REFORMULATED COATINGS
There are two basic types of reformulated coatings that can be used by the wood
furniture industry to reduce VOC and VHAP emissions: waterborne coatings and higher
solids coatings. Because the NESHAP restricts only the VHAP content of coatings, facilities
may also choose to use another type of reformulated coating that will reduce VHAP
emissions but not VOC emissions. For lack of a better term, these coatings will be referred
to as solvent substituted coatings in this discussion.
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6.1.1 Waterborne Coatings
' Although~waterborne coatings are- typically higher solids coatings than the traditional
nitrocellulose lacquers used by many wood furniture manufacturers, they can be distinguished
from other higher solids coatings by the fact that some portion of the solvent is water.« All
types of coatings can be reformulated as waterborne coatings. Waterborne stains, washcoats,
sealers, and topcoats are available. Some plants use a complete waterborne system, while
others have reformulated only some of their coatings and are using either a hybrid or a
reverse hybrid waterbome finishing system. In a hybrid waterborne system, the topcoat may
be a waterborne coating or the sealer and topcoat may both be waterborne coatings. In a
reverse hybrid system, the stains and toners, and sometimes the washcoats, are waterborne
coatings.
It is difficult to identify the advantages and disadvantages of waterborne coatings,
because the advantages and disadvantages may be different depending upon the type of
coating to which the waterborne coatings are compared. For example, waterborne coatings
have the advantage of being more durable and having better chemical resistance than the
traditional nitrocellulose lacquers used by most residential furniture manufacturers.
However, compared to conversion varnishes, which are used extensively by the kitchen
cabinet industry because of their durability and resistance to chemicals, the durability and
chemical resistance of waterborne coatings may be a disadvantage. The inability of
waterborne coatings to-rewet and their poor workability are disadvantages when compared to
nitrocellulose lacquers, but conversion varnishes present some of the same problems.
The cost of converting to waterborne finishes can be significant. The total cost to the
facility will depend upon how many finishing steps are reformulated to waterborne.
Facilities converting to waterborne coatings may have to make a significant capital
investment. Equipment that may be required includes:
- Passivated stainless steel transfer lines and mix tanks;
- Storage building to replace outdoor bulk storage; and
- Ovens to facilitate drying of the coating.
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In summary, the advantages of waterborne coatings include:
- Low VOC and VHAP content;
- Better durability and chemical resistance than nitrocellulose lacquers; and
- Possibly lower insurance costs for the facility.
Disadvantages of waterborne coatings include:
- Slower drying time;
- Cost;
- Clarity of finish; and
- Workability/repairability.
As discussed in Chapter 2, one of the reference-control technologies for the CTG is
the use of waterborne topcoats with a VOC content no greater than 0.8 Ib VOC/lb solids, as
applied. If all of a facility's topcoats are waterborne coatings with a VOC content no greater
than 0.8 Ib VOC/lb solids, as applied, they are in compliance with the CTG. If a facility
wished to use a reverse hybrid finishing system, they would have to average their emissions
to demonstrate they are achieving the required emission reduction. Chapter 4 includes an
example of a facility using a reverse-hybrid system and an averaging approach to comply
with the requirements of the CTG.
Waterborne coatings can also be used to meet the NESHAP emission limits for
finishing. A facility could reformulate all of their coatings that are subject to an emission
limit under the NESHAP to waterborne coatings and likely be able to meet the emission limit
of 1.0 Ib VHAP/lb solids, as applied, (0.8 Ib VHAP/lb solids, as applied, for new sources).
However, a facility will probably not have to reformulate all of their coatings to waterborne
coatings in order to meet the NESHAP emission limits. Because the NESHAP allows
facilities to average their emissions across coatings, a facility may use a combination of
waterborne coatings and traditional solventborne coatings to meet the average emission limit
of 1.0 Ib VHAP/lb solids, as applied (0.8 Ib VHAP/lb solids for new sources).
Table 6-1 presents scenarios in which waterborne coatings can be used to meet the
CTG and/or NESHAP emission limits for coatings.
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TABLE 6-1. USING WATERBORNE FINISHING SYSTEMS TO MEET THE CTG
AND NESHAP EMISSION LIMITS
Finishing system
Hybrid waterborne
-Topcoat only
-Sealer & topcoat
Reverse hybrid
Full waterborne
Comply with CTG?
Yes
Yes
Maybe0
Yes
Comply with NESHAP?
No*
Maybe"
Maybeb
Yesd
"To comply with the NESHAP, all major coatings must have a VHAP content no greater
than 1.0 Ib VHAP/lb solids, as applied (0.8 Ib VHAP/lb solids for new sources) or
the average across all-coatings must be no greater than 1.0 (0.8 for new sources). If
the facility were using waterborne topcoats and the other coatings were conventional
coatings, which would probably not meet the emission limit, the facility would not be
hi compliance with the NESHAP. They could try to use an averaging approach, but
with all coatings besides the topcoat being conventional coatings, they would probably
not meet the limit.
bAs with the facility using waterborne topcoats only, the other coatings would likely not
meet the limit of 1.0 (or 0.8 for new sources) so the facility could probably not
comply using a compliant coatings approach. However, with waterborne sealers and
topcoats (or in the case of the reverse hybrid system, waterborne stains and
washcoats), the average VHAP content across all of the facility's coatings may be less
than 1.0 (or 0.8 for new sources), so they may be able to comply using an averaging
approach.
^Because me'referencecontrol technologies are based on reformulated topcoats or
reformulated sealers and topcoats, the facility would have to use an averaging
approach to comply with the CTG. The facility would have to demonstrate that then-
emissions are no greater than 90 percent of what they would be using one of the
reference control technologies.
"Even with a full waterborne system, it is possible the facility would have to use an
averaging approach rather than a compliant coatings approach to comply with the
NESHAP. Some waterborne stains may not have a VHAP content less than 1.0 Ib/lb
solids.
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6.1.2 Higher Solids Coatings
Many types of coatings can be considered higher solids coatings. The acid-catalyzed
coatings used by business furniture and kitchen cabinet manufacturers are higher solids
coatings when compared to the nitrocellulose lacquers used by residential furniture
manufacturers. However, the solids content of the acid-catalyzed coatings is low in
comparison to the solids content of ultraviolet (UV)-cured coatings. This discussion will
focus on higher solids coatings that meet the CTG limits for higher solids sealers and
topcoats.
6.1.2.1 UV-Cured Coatings. Many segments of the wood furniture industry are
using UV-cured coatings. These coatings cure via polymerization when exposed to UV
radiation. The final film is very resistant to chemicals and scratching. While the final film
provides excellent durability, some manufacturers consider the finish too glossy. Ultraviolet-
cured coatings have a very low VOC and VHAP content, with solids contents ranging from
n*
85 to 100 percent. These coatings easily meet the CTG limits for higher solids sealers and
topcoats and the even more stringent limits for waterborne topcoats. To date, UV-cured
coatings have been used primarily in flatline finishing systems where all surfaces of the
V
pieces to be finished can be easily exposed to UV radiation. However, the use of 3-D UV-
curing systems, which can be used on conventional spray lines, is increasing.
In summary, UV-cured coatings have the following advantages:
- Finish has excellent durability and is resistant to chemicals and scratching;
Curing is rapid so finished pieces can be stacked almost Immediately; and
- Very low VOC and VHAP content, up to 100 percent solids.
Disadvantages of UV-cured coatings include:
- Finish is considered to be too glossy;
- Problems still exist in finishing 3-D pieces; and
- Finish cannot be spot repaired.
As discussed earlier, UV-cured coatings easily meet the emission limits established
for the CTG. Because the NESHAP limits the VHAP content of the color coats also,
facilities using UV-cured topcoats would also have to reformulate their color coats if they
wanted to use a compliant coatings approach to meet the NESHAP limits. However, these
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facilities could use UV-cured topcoats and use an averaging approach to meet the NESHAP
iimks;
6.1.2.2 Polvester/Polvurethane Coatings. Polyester and polyurethane coatings are
both being used in the wood furniture industry. To date, however, their use has been fairly
limited.
There are two types of polyester finishes being used by the wood furniture industry:
styrene-derived polyester coatings and acrylic polyesters. Both types of coatings cure
through either a catalytic reaction or exposure to UV radiation. Both types of coatings have
very low VOC and VHAP contents. The styrene-derived coatings are typically 100 percent
solids and the acrylic polyesters are approximately 80 percent solids. Although the
styrene-derived polyesters are approximately 100 percent solids coatings, some styrene may
not cross-link and may be emitted during the curing process.
•Polyesterfinislies' provide good build and good chemical-, mechanical-, and heat
resistance. However, because they are difficult to repair, it may be necessary to install a
clean room to minimize dust. The coatings also have a short pot life.
Polyurethane coatings also cure through a catalytic reaction. They have many of the
same advantages and disadvantages of polyester coatings. The finish is durable and provides
good chemical and mechanical resistance. As with polyester coatings, however, a clean
room may be required. The VOC content of polyurethane coating varies greatly, ranging
fc^O»2S.toift»3^¥
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- Difficulty of repair—a clean room environment may be required;
- The finish may be too glossy;
- Facilities subject to the NESHAP using styrene-derived polyester coatings will have
to track their styrene emissions under the formulation assessment plan; and
- Additional worker protection is required for facilities using polyurethane coatings.
6.1.2.3 Higher Solids Nitrocellulose Lacquers. Several wood furniture coating
suppliers have developed higher solids nitrocellulose coatings. In terms of finish appearance
and durability, these coatings offer the same advantages and disadvantages of conventional
nitrocellulose lacquers. The solids contents of these coatings ranges from 30 percent to
50 percent by weight. They meet the CTG emission limits for higher solids sealers and
topcoats. Advantages of these coatings include:
Low VOC and VHAP content; and
- Appearance is comparable to finish with conventional nitrocellulose lacquers.
Disadvantages include:
- Potential increase in drying time; and
- Cost. (The facility has to purchase special application equipment.)
6.1.2.4 Summary of Hieher Solids Coatines. All of the higher solids coatings
•discussed here can be used to meet the CTG emission limits. In some cases, the facility will
only have to reformulate their topcoats, because the coatings have a VOC content less than
0.8 Ib VOC/lb solids, as applied. For some of the finishing systems, the facility will have to
reformulate their sealers and topcoats to meet the limits of 1.9 Ib VOC/lb solids and 1.8 Ib
VOC/lb solids, respectively.
Facilities can also use these higher solids coatings to help meet the NESHAP emission
.limits. However, hi most cases, they would also have to reformulate their color coats,
iparticularly, if they wanted to use a compliant coatings approach to comply with the
NESHAP. In some cases, the VHAP content of the reformulated clear coats may be low
enough that the facility can use an averaging approach to comply with the NESHAP without
reformulating their color coats.
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6.1.3 Solvent-Substituted Coatings
The NESHAP only limits the VHAP content of coatings. Facilities that are not
subject to the CTG do not necessarily have to use lower VOC coatings to meet the NESHAP
emission limits; they only have to use lower VHAP coatings. While some VOC are VHAP,
many are not. Therefore, wood furniture manufacturers can choose to meet the NESHAP
emission limits by substituting non-VHAP solvents for solvents that are VHAP. For
example, methanol, a VHAP, is commonly used as a solvent in stains. In some cases,
ethanol, which is not a VHAP, may be substituted for some or all of the methanol.
It is difficult to foresee the advantages or disadvantages of using this approach to meet
the NESHAP emission limits, because this is an option that is just beginning to be
investigated. One potential disadvantage is that the list of 189 HAP's may change. Facilities
may reformulate their coatings with a solvent that is later added to the list. However,
chemicals cannot be added to the list without extensive review, so industry will have advanc^
notice of any potential changes. In addition, the NESHAP includes specific language
addressing this issue. If chemicals are added to the list, the emission limits will likely be
adjusted upward or facilities will be given additional time to meet the limit. One advantage
is likely the cost of solvent substitution versus reformulating to waterborne coatings or higher
solids coatings. There will undoubtedly be some cost in substituting solvents, but it is likely
to be less than moving to either waterborne coatings or most of the higher solids coatings.
6.1.4 Using a Combination of Reformulated Coatings
The reality is that many facilities will likely choose to use a combination of
reformulated coatings to meet the CTG and/or NESHAP emission limits. A facility may find
that waterborne topcoats work fine for one product line, but they need to use higher solids
sealers and topcoats on another product line. To meet the NESHAP emission limits, a
facility may move to higher solids sealers and topcoats and use solvent-substituted stains.
The CTG and NESHAP both provide facilities the flexibility to use any of the reformulated
coatings discussed earlier, or a combination of these reformulated coatings.
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6.2 ADD-ON CONTROL DEVICES
As discussed earlier, most facilities are expected to use reformulated coatings to meet
the CTG and/or NESHAP emission limits. The use of add-on control devices will likely
continue to be limited to large facilities with automated flatline finishing systems. In
general, these are the only operations for which the use of add-on controls is cost effective.
Therefore, this section will only provide a brief description of the types of add-on controls
available.
6.2.1 Oxidizers
Oxidizers destroy VOC's by converting them to carbon dioxide (CO^) and water.
There are two main types of Oxidizers available for controlling emissions from wood
furniture finishing operations: thermal.oxidizers and catalytic oxidizers.
6.2.1.1 Thermal Oxidizers. Thermal oxidizers heat the waste gas stream to an
adequate temperature and hold the stream at that temperature for a sufficient time to oxidize
the organic compounds in the waste gas stream. Primary components of a thermal
oxidization unit are a fan, a heat recovery device, a combustion chamber, and an exhaust
stack. The heat recovery device preheats the incoming waste stream in order to minimize the
auxiliary fuel requirements in the combustion chamber. Well designed and operated thermal
oxidizers can destroy more than 98 percent of the organics present in the waste stream.
It is technically feasible to control both VOC and VHAP emissions from wood
furniture finishing operations with a thermal oxidizer. The compounds present in wood
furniture exhaust streams (aromatic hydrocarbons, ketones, acetates, and alcohols) can be
readily converted to CO2 and water with a thermal oxidizer. However, the costs associated
with control of a dilute air stream can be very high due to supplemental fuel requirements.
That is why thermal oxidizers are currently being used primarily on automated, flatline
finishing systems. Because worker exposure is not as much of an issue with automated
finishing systems, the air flows are much lower so the exhaust stream is more concentrated.
In summary, the only real advantage of thermal oxidizers is that they can achieve a
significant reduction, at least 98 percent, in both VOC and VHAP emissions. The primary
disadvantage is the cost.
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6.2.1.2 Catalytic Oxidizers. Catalytic oxidizers are similar to thermal oxidizers.
However, with catalytic oxidation, the oxidation temperature is considerably lower because a
catalyst is used to promote oxidation. Platinum is the most commonly used catalyst.
Components of a catalytic oxidation unit include a fan, a preheat burner, a combustion
mixing chamber, a catalyst chamber, a waste gas preheater, and secondary heat recovery
It is technically feasible to use catalytic oxidation to control emissions from wood
furniture finishing operations. However, there are some technical issues involved with
catalytic oxidizers that are not issues with thermal oxidizers. A constant gas flow rate and
concentration is recommended for optimal operation of catalytic oxidizers. Wood furniture
exhaust streams vary in both composition and concentration. In addition, the presence of
paniculate matter in wood furniture exhaust streams can poison the catalyst and reduce the
catalyst life. This particulate matter would have to be removed using filtration. Of the
dozen or so oxidizers currently being used by wood funutttfe-manufacflirers,,only .one is.a,.^
catalytic oxidizer. All the others are thermal oxidizers.
6.2.2 Carbon Adsorbers
With a carbon adsorber, the VOC in the waste gas stream are adsorbed onto an
activated carbon bed. The collected compounds can then be recovered, if desired, by
desorbing the bed with steam or hot air. This desorption process is known as regeneration.
After regeneration, the VOC can be condensed and recovered or disposed of. Alternatively,
if hot air is 'used-for-regeneration, the VOC can be sent to an oxidizer for destruction.
The components of a fixed-bed, regenerable carbon adsorption system include a fan,
at least two fixed-bed carbon adsorption vessels, a steam valve for introducing desorbing
steam, a condenser for the steam/contaminant desorbed stream, and a decanter for separating
the VOC condensate and water. If hot air is used for regenerating the bed, a condenser and
decanter are not required. The air stream could be sent to an oxidizer for final destruction of
the VOC.
Carbon adsorption is technically feasible for controlling wood furniture exhaust
streams. Well-designed and operated carbon adsorbers can achieve a recovery efficiency of
95 percent. However, carbon adsorption followed by steam regeneration and subsequent
condensation is not a good choice for controlling VOC emissions from most wood furniture
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finishing operations because of the number of different types of solvents that are present in
most wood furniture exhaust streams. Condensing and distilling many different solvents is
complicated, and the purity of such distilled solvents limits their use. Carbon adsorption
followed by hot air regeneration is a more practical solution for wood furniture exhaust
streams. The air stream can then be sent to an oxidizer where the VOC are destroyed.
While this may seem more expensive than using an oxidizer only, in some cases it is not.
The air stream from the carbon bed is concentrated, so a smaller oxidizer can be used. The
more concentrated air stream also has a higher heating value, so that less auxiliary fuel is
required.
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CHAPTER?
OVERVIEW OF THE TITLE V OPERATING PERMIT ^PROGRAM
BACKGROUND
The 1990 Clean Air Act Amendments established a new permit program for stationary
sources. The program is included in Title V of the Clean Air Act, so the permits required
by this program are often known as Title V permits. They are also referred to as operating
permits.
The purpose of the Title V permit program is to provide a mechanism for combining
all of a facility's air emission requirements and limitations into one permit. Currently,
facilities may have a number of different permits that pertain to their air emissions or
limitations on those emissions. This chapter will present a brief overview of the Title V
operating permit program, particularly as it relates to the CTG and NESHAP.
7.2 INFORMATION TO BE INCLUDED IN AN OPERATING PERMIT
While the requirements may vary slightly from State to State, the following
information must be included in each permit:
- Basic facility information, e.g., location, SIC code, legal owner, plant contact;
- Process and product descriptions;
- Emission points, emission rates, and pollutants;
- Control devices, other control measures;
- All applicable State and Federal requirements; and
- Compliance plan and certification.
Applicable State and Federal requirements include any new source performance
standards (NSPS) or NESHAP to which the source may be subject and any RACT or BACT
requirements. However, there will be facilities that, even though they are major sources,
will not be subject to any State or Federal requirements. These facilities will still have to
have a permit, but all they will have to do is report their emissions on a regular basis. These
permits are referred to as "hollow permits". Even sources that will be subject to the wood
furniture NESHAP will likely not have these requirements included in their first permit
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application, because the compliance date for the NESHAP is not until November 1997 or
December 1998 depending on the facility's total emissions. However, the application should
include a statement that the source will meet any requirements that become effective during
the permit period.
7.3 REPORTING REQUIREMENTS ASSOCIATED WITH THE OPERATING
PERMIT
The Tide V operating permit program requires facilities to submit a compliance
certification annually, unless the facility is subject to a Federal or State requirement that
requires sources to submit a report more often. The semiannual compliance status reports
required by both the CTG and NESHAP are consistent with this requirement. These reports
have to be submitted twice a year rather than once a year, but the information requirements
are the same as those associated with the operating permit program requirements.
7.4 RELATIONSHIP TO THE CTG AND NESHAP
Sources that are subject to the NESHAP will have to obtain a Title V operating
permit. Many of the sources subject to the CTG will also have to obtain a Title V operating
permit, but there may be some that will not. The applicability limit for the CTG is 25 tons
of VOC per year, unless the source is located in an extreme nonattainment area. However,
the major source designations for VOC emissions are higher than 25 tons per year in serious,
moderate, and marginal nonattainment areas and in the ozone transport region. For sources
in moderate and .marginal nonattainment areas, the cutoff is 100 tons per year. Therefore,
sources in these areas emitting between 25 tons and 100 tons of VOC per year would be
subject to the CTG, but they would not be considered major sources based on their VOC
emissions. The major source designation cutoff in serious nonattainment areas and in the
ozone transport region is 50 tons of VOC per year. Therefore, sources in these areas
emitting between 25 and 50 tons of VOC per year would be subject-to the CTG, but .they
would not be major sources based on their VOC emissions. In both cases, these facilities
would not have to obtain a Title V permit, unless they were also subject to the NESHAP.
Wood furniture facilities can use Table 7-1 as a guide for determining if they are required to
obtain a Title V permit.
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TABLE 7-1. WOOD FURNITURE FACILITIES REQUIRED TO OBTAIN
A TITLE V PERMIT
Scenario
Title V Permit
Required?
Subject to the NESHAP
Yes
1. Subject to the CTG; and
2. Located in a severe or extreme nonattainment area.
Yes
1. Subject to the CTG;
2. Located in a serious nonattainment area or the ozone transport
region; and
3. Potential VOC emissions are greater than 50 tons per year.-*
Yes
1. Subject to the CTG;
2. Located in a serious nonattainment area or the ozone transport
region; and
3. Potential VOC emissions are less than 50 tons/yr.
No1
1. Subject to the CTG;
2. Located hi a marginal or moderate nonattainment area; and
3. Potential VOC emissions greater than 100 tons/yr. r
Yes
1. Subject to the CTG;
2. Located in a marginal or moderate nonattainment area; and
3. Potential VOC emissions less than 100 tons/yr.
Noa
*A Title V operating permit will be required if the facility is subject to the NESHAP.
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7.5 TIMEFRAME FOR SUBMTTTING AN APPLICATION FOR A PERMIT
The date fb^subraitting'an application for a Title V operating permit will vary from
State to State, and in some cases, within different areas of the State. While Part 70 of the
Code of Federal Regulations (CFR), which includes the regulations developed in response to
Title V, provides clear timelines for the permitting process, both the States and EPA have -
fallen behind in meeting these dates. Table 7-2 presents the schedule for the permit program
included in Part 70,
TABLE 7-2. ORIGINAL SCHEDULE FOR THE TITLE V PERMIT PROGRAM
Permit Program Activity
State submits permit program to EPA for
approval
EPA approves permit program
Facility submits permit application
Final action on permit applications by
State
Scheduled Date
November 1993
November 1994
No later than November 1995
Not to exceed three years;
on 1/3 of applications each
State must act
year.
Some States are close to following this schedule. They submitted their permit
programs on time and have received approval from EPA. Some are even requiring facilities
to submit their permit applications earlier than November 1995, in order to avoid being
deluged with applications at that time.
However, there are many more States that have not yet received approval of their
permit programs. A few have not even submitted their permit programs to EPA. Therefore,
many facilities will not have to submit dieir permit applications until after November 1995.
In summary, facilities should contact their permitting authority (State or local agency)
to determine the date by which they will be required to submit their permit application.
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CHAPTERS
DEVELOPING A POLLUTION PREVENTION PROGRAM AT TOUR FACILITY
This chapter addresses the steps a facility should take in developing a pollution
prevention program to reduce emissions to the air. However, facilities are encouraged to
develop a multimedia waste reduction program that addresses methods for reducing solid
waste, energy usage, and raw material usage. The U. S. Environmental Protection Agency
and the Tennessee Valley Authority have produced a manual entitled "Wood Furniture Waste
Reduction Opportunities" that offers a guide to multimedia waste reduction opportunities
from all areas of the wood furniture manufacturing process. The manual is available from
the EPA's Center for Environmental Research Information [(513)'-S69-7391].
While the focus of this chapter is on pollution prevention practices that facilities can
implement to reduce air emissions, many of these practices also have other beneficial impacts
such as reducing worker exposure to solvents and reducing the use of raw materials.
8.1 WHERE DO I START?
While the answer to this question may vary from one facility to another, the following
basic steps should serve as a good starting point.
1. Getting a Commitment
Keys to success for this step include:
- Obtaining a commitment from management to support the program, including a
commitment of resources;
- Obtaining a commitment from plant engineers/department supervisors to oversee
the program;
- Educating the operators concerning the benefits of the program and the importance
of their role; and
- Obtaining a commitment from the operators.
2. Forming a Committee
The next step is to form a committee to evaluate each area of the facility's operations
to determine where pollution prevention practices can be instituted. The committee should
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include representatives from all operations, including lumber receiving/drying, rough end,
assembly, finishing, packing and shipping, «nd maintenance. This ensures the committee has
members with expertise in each area, but it also accomplishes another objective. Many times
it is difficult for people to see the obvious in areas where they work every day, but they
provide fresh eyes that instantly recognize pollution prevention opportunities in other areas of
the plant. The committee should also include upper management representatives, department
supervisors, and operators. If possible, committee members should be volunteers. Someone
who is forced to serve on the committee is less likely to be committed to achieving the
committee's goals than someone who has volunteered. In order to ensure volunteers are
available, management should make sure that department supervisors and operators are
allowed time away from their other obligations to work with the committee.
Keys to success for this step include:
- Including tipper management, plant engineers/department supervisors,, and •operators.
on the committee;
- Including representatives from each area of operation;
- Having volunteers rather than draftees serve on the committee; and
- Allowing committee members time away from their other obligations to participate
in committee activities.
3. Assessing Each Area of Operation
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- Willingness of committee members to present ideas in followup committee meeting;
and
- Consolidating ideas into a concise list of recommendations that can be presented to
management.
4. Reporting Back to Management
As a group, the committee should report back to management at this time to present
their recommendations based on the facility assessment. While the recommendations may
include specific pollution prevention practices the committee believes should be implemented,
it is likely that the recommendations will be more general ideas such as the committee
believes they are ready to begin development of a pollution prevention plan or they feel a
more detailed assessment is needed before developing the plan.
The real key to success for this stage is the willingness of all committee members to
tjie honest with management. If they have seen one area of operation that seems to have
extensive problems and needs major improvements, they should be willing to communicate
-.this information. They also should be willing to put forth ideas, not just criticisms.
5. Detailed Assessment of Pollution Prevention Practices
During the preliminary assessment of each area of operation, it is likely that the
^committee identified several ideas for pollution prevention practices that could be
implemented in each area. The committee should follow up on these ideas with a more
detailed investigation. At this time, the committee may split up into smaller groups with
each group responsible for one area. This should increase their productivity. They may also
want to bring in more expertise from each area to assess the feasibility of their ideas. In
performing a detailed assessment of potential pollution prevention practices, these groups
should address the following questions:
- What are the benefits associated with the proposed measure, for example, cost
savings, reduction in raw material usage, positive impact on the environment;
- What are the disadvantages, for example, high cost to the facility, potential
negative impact on product quality;
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Has the facility attempted to implement the measure before, what problems did they
-encounter, why did they decide; not to continue, have they learned anything since that time or
has the technology changed so that the measure might be successful now;
- Do the benefits outweigh the disadvantages; and
- Is implementing the pollution prevention practice a high priority item or is it
something that could wait until a later date?
After answering each of these questions, the group should be ready to report back to
the full committee with a list of recommendations and a priority list for implementing the
recommended practices.
Keys to success for this step include:
- Asking the right questions; and
- Doing the research that is necessary to answer them.
6. Developing the Pollution Prevention Plan
After each of the committee groups has finished the detailed assessment for their
assigned area, the committee should reconvene. Each group should have prioritized the
recommendations for their assigned area. The committee may then want to take each of
these prioritized lists and develop a list of priorities for the whole facility. Those with the
highest priority should be implemented first, but all of the recommended practices should be
included in the pollution prevention plan.
However, a list of pollution prevention practices is just a part of the plan. The plan
should also include the following information:
- A description of the goals of the program;
- Methods for documenting that the recommended practices have been implemented,
including check lists that in-house inspectors can use as they walk through the facility.
Figure 8-1 includes an example check list that a facility might use as the basis for
inspections;
- Methods for documenting the results;
- Guidance to employees on where to go with any suggestions they may have;
- A schedule for regular meetings of the committee; and
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WORK PRACTICE INSPECTION CHECKLIST
Date of Inspection
Date of Last Inspection
: '•Name of Inspector
Work Practice
Yes
No
Finishing Operations
'Are the operators using proper application techniques?
Are there any open containers of solvent?
Are there any open containers of coating?
Are the mix tanks closed when not in use?
Are there any open barrels containing solvent impregnated
rags?
Gluing Operations
Are the operators using proper application techniques?
Are there any open containers of solvent?
Are there any open containers of adhesives?
Cleaning and Washoff Operations
Are the operators using proper procedures for cleaning spray
guns?
Are the operators using proper procedures for cleaning
transfer lines?
Is the washoff tank covered when not in use?
Are the operators tracking the number of pieces washed off
and the reasons why?
Are pieces that are being washed off allowed sufficient time
to drain off excess solvent into the washoff tank before being
moved?
Figure 8-1. Example checklist for documenting work practice
standards are being implemented.
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- A mechanism for reviewing the plant's operations regularly so that any changes can
be evaluated and potential pollution prevention practices can be incorporated.
8.2 POLLUTION PREVENTION PRACTICES FOR THE WOOD FURNITURE
INDUSTRY
So what pollution prevention practices are available for a wood furniture facility?
Well, one place to start is the work practice standards for the CTG and NESHAP that are
presented in Chapter 3. All of these work practice standards are commonly used pollution
prevention practices in the wood furniture industry. They were developed as a part of the
regulatory negotiation, with input from facilities that had implemented the practices and a
State office of waste reduction that has done considerable work with the wood furniture
industry. Even if a facility is not subject to the CTG or the NESHAP, it should evaluate the
applicability of the work practice standards to the facility. Reformulating coatings to meet
the CTG and/or "NESHAP -emission limitations is also a pollution prevention method-
The four major sources of air pollution at wood furniture manufacturing facilities are
finishing, cleaning, washoff, and gluing. Following is a discussion of pollution prevention
practices for each of these emission'sources. Undoubtedly, this is not a complete list.
Because wood furniture manufacturing processes vary extensively within the industry, some
of these practices may not be applicable to a specific facility. There may be other pollution
prevention practices not listed that have already been implemented at the facility. Hopefully,
these work practices will .serve as a good starting point, and they can be used to form the
groundwork for a site specific pollution prevention plan.
8.2.1 Finishing Operations
Many of the work practice standards discussed in Chapter 3 are pollution prevention
practices that can be used to reduce both emissions and coating usage. A brief discussion of
these and other pollution prevention practices for finishing operations is presented below.
8.2.1.1 Application Equipment. Both the CTG and the NESHAP limit the use of
conventional air spray guns. While studies show varying results concerning the transfer
efficiency of different spray guns, most indicate that conventional air spray guns are the least
efficient. Because there is no clear cut advantage for other types of guns, for example, high
volume low pressure (HVLP) versus air assisted airless, neither the CTG or the NESHAP
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mandate what type of application equipment must be used. Facilities should test different
types of application equipment to determine which type best meets their performance needs.
There is no one answer that is right for every facility. In some cases, a facility may find
that one type of gun is better for applying clear coats while another type is better for
applying color coats.
If a facility is changing application equipment, it needs to make sure the operators are
trained with the new equipment. Different types of application equipment require different
application techniques. An operator may have 20 years of experience applying coatings with
a conventional air spray gun, but that does not mean he or she is qualified to use an HVLP
gun. Without proper operator training, the potential increase in transfer efficiency associated
with the new application equipment may be more than offset by improper application
techniques.
In summary, switching to more efficient application equipment can have the following
benefits:
- Reduction in emissions;
- Reduction in coating usage and coating .cost; *md
- Possible reduction in solid waste because filters may not have to be changed as
often.
However, in switching to more efficient application equipment some of the following
problems could be encountered:
- Extensive testing of new application equipment may be required to determine the
best equipment for the facility's applications;
- Operators will probably need to be retrained with new equipment; and
- A facility with a particularly fast finishing line may not be able to use some of the
T higher efficiency types of spray guns because some of the guns have a slower delivery rate.
8.2.1.2 Operator Trainine. Both the CTG and NESHAP require operators to be
trained on an annual basis. However, this practice should be implemented at each facility
whether it is subject to these standards or not. While type of application equipment is a
factor in transfer efficiency, operator training may be even a bigger factor. As discussed
earlier, this is particularly true when a facility introduces new application equipment
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requiring different application techniques. It is also true when facilities have reformulated
4hek-«oatings. Application techniques for waterbome coatings are different than those for
solventborne coatings.
Providing extensive training for spray booth operators can reduce coating usage and
as a result, reduce operating costs. Well trained spray booth operators can also improve the
quality of the product. Using proper application techniques may also reduce the spray booth
operator's exposure to solvents. Operators should be retrained each year. This should help
keep them from picking up bad habits that may reduce transfer efficiency, have a negative
effect on product quality, and increase their exposure to solvents.
Section 8.3 presents guidance on developing an-operator training program and a
discussion of the information that should be included.
Potential advantages of instituting an operator training program include:
- Reduction in emissions;
- Reduction in coating usage and cost;
- Improvements in product quality; and
- Reduction in worker exposure to solvents.
There are really few, if any, disadvantages associated with an operator training
program. While there are some costs involved with the training, these may be offset by
savings in other areas.
8.2*1.3 Inspection and Maintenance Plan. All equipment used to store, transfer, or
apply coatings or solvents should be checked regularly for leaks or other malfunctions.
Leaking equipment results not only in emissions but also in a loss of materials and additional
cost to the facility. It also increases worker exposure to solvent. While some leaks may be
obvious and noticed immediately, small leaks in less traveled areas may go undetected
without a regularly scheduled inspection. Figure 8-2 is an example of a checklist facilities
can use to document that the scheduled inspection has been conducted.
8.2.1.4 Reformulated Coatings. Obviously, reformulating coatings so that they
contain less organic solvent offers the greatest opportunity for reducing emissions from
finishing operations using pollution prevention practices. A discussion of the reformulated
coatings available and their advantages and disadvantages is presented in Chapter 6.
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EQUIPMENT INSPECTION CHECKLIST
Date of Inspection
Inspector's Name
Date of Last Inspection
Area 1 (e.g.. mix room)
Visible leaks/malfunctioning equipment (Yes/No)
Source of leak
Description of equipment and malfunction
Description of repairs
Date of Repairs
Area 2 (e.g.. transfer lines from mix room to spray booths)
Visible leaks/malfunctioning equipment (Yes/No)
Source of leak
Description of equipment and malfunction
Description of repairs
Date of Repairs
Area 3 (e.g.. spray booth 1)
Visible leaks/malfunctioning equipment (Yes/No)
Source of leak ___
Description of equipment and malfunction
Description of repairs
Date of Repairs
Figure 8-2. Example checklist for equipment inspection program.
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Facilities should carefully evaluate the alternatives available and select the ones that best fit
their needs.
8.2.1.5 Other Pollution Prevention Practices for Finishing. Following is a list of
other pollution prevention practices related to finishing that facilities may want to implement.
Some of these are requirements of the CTG and NESHAP and some are not.
(1) Keep all tanks used for storing coatings, particularly mix tanks, covered at all
times. This reduces coating and solvent usage and reduces worker exposure to solvents.
(2) Keep barrels containing used rags covered at all times. Many facilities use rags
to wipe off excess stain or to polish pieces after finishing. These rags can then be a source
of emissions. To minimize emissions from these rags, "keep barrels handy for storing them
and keep those barrels closed. Again, this will not only reduce emissions, but it will also
reduce worker exposure to solvents.
(3) In many facilities, coatings are thinned with solvent before, application .to adjust
the viscosity. There may be some instances where the facility could heat the coating to
reduce its viscosity rather than thinning it with solvents.
(4) Maintain spray guns in good operating condition. Make sure that any regular
maintenance procedures recommended by the vendor are followed.
8.2.2 Gluing Operations
Most of the pollution prevention practices that are applicable to finishing operations
are also applicable to gluing operations. These include the following:
- Discontinuing the use of conventional air spray guns to apply adhesives;
- Training operators in proper application techniques;
- Checking for equipment leaks and malfunction;
- Reformulating adhesives; and
- Keeping containers used for storing adhesives closed.
Note that the limitation on conventional air spray guns included in the CTG and
NESHAP does not include guns used to apply adhesives. However, facilities should
investigate the use of alternatives to conventional air spray for the application of adhesives.
This will improve transfer efficiency, thereby reducing emissions and adhesive usage.
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8.2.3 Cleaning Operations
There are a number of pollution prevention practices for cleaning operations that,.
facilities can implement to reduce emissions, reduce cleaning solvent usage, and reduce
worker exposure to solvents. Many of these pollution prevention practices are included as
work practice standards in the CTG and NESHAP.
8.2.3.1 Cleaning Solvent Accounting System. Many facilities do not really have a
good idea of how much cleaning solvent they use and what it is used for. The first step in
reducing cleaning solvent usage is to collect this information. Facilities should implement a
system for determining the amount of cleaning solvent they use each month and where it is
used, for example, cleaning spray guns, cleaning spray-booths, cleaning transfer lines, etc.
Facilities can then target those areas of.highest use for reductions.
In some cases, cleaning solvent is reused as thinner for coatings. It may also be
collected and sent offsite for disposal. By tracking the fate of used cleaning solvent, the
facility will be able to determine the net amount of cleaning solvent that is lost, that is,
emitted each month.
One way to control the amount of cleaning solvent used is to have a checkout system.
Operators are given only enough solvent at the beginning of their shift to perform the
cleaning needed. This allows the facility to keep track of the amount of cleaning solvent
used and is a mechanism to ensure some operators are not wasting cleaning solvent.
8.2.3.2 Gun/line Cleaning. Pollution prevention practices related to spray gun and
line cleaning that may be implemented include:
- Collect solvent used to clean the spray guns and lines into a container, which is
subsequently closed, rather than spraying the solvent into the booth;
- Use duty solvent for the initial cleaning, followed by clean solvent for the final
cleaning. The clean solvent can then be reused for cleaning or for thinning coatings;
- Dispose of duty solvent by contracting with a firm that distills the solvents for
reuse or distill the solvents onsite for reuse;
- As much as is practical, facilities should schedule finishing operations for the day
so that lighter color coats are applied early in the day and darker color coats are applied
later. This should minimize the need for spray gun and line cleaning; and
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When possible, air pressure should be used instead of solvent for cleaning lines.
8.2.3.3 Sprav Booth Cleaning. Almost all facilities are now-using strippable spray
booth coatings to reduce the need for solvent cleaning of spray booths. If your facility is not
already using these coatings, this is a relatively easy way to reduce cleaning solvent usage.
At a minimum, you should use cardboard or some other material to protect the spray booth
walls from overspray, thereby minimizing the need to use solvent for cleaning.
8.2.3.4 Use of Alternative Cleaning Materials. The EPA is evaluating alternatives to
the cleaning solvents, primarily lacquer thinner, currently being used by the industry. In
some cases, lower vapor pressure solvents can be used in place of the solvents currently
being used. Because of their lower vapor pressure, less of this solvent should be emitted
during the cleaning process. While this option should be explored, facilities should conduct
a careful investigation before changing cleaning materials. If the new cleaning solvent is not
as effective at removing dried "coating, the facility may end up using more solvent* .thereby
offsetting the benefits of the lower vapor pressure solvent.
8.2.3.5 Operator Training. Operators should also be trained in proper cleaning
procedures. They should be shown the proper methods for cleaning spray guns and transfer
lines. They should also be educated concerning the negative impacts of improper use of
cleaning solvents. Many operators become immune to the fact that they are handling
potentially dangerous solvents. They do not realize that the solvents are not only a source of
emissions but-are-also potentially hazardous.
8.2.4 Washoff Operations
Washoff is the process of removing dried coating from the furniture. In many cases,
the same solvents used for cleaning are also used for washoff. Following is a brief
description of pollution prevention practices that may be implemented to reduce washoff
solvent usage and emissions from the washoff process.
8.2.4.1 Washoff Solvent Accounting System. As with cleaning solvent usage, many
facilities do not have a good idea of how much solvent they use for washoff. Therefore, the
first step is to implement a system to account for the amount of solvent used for washoff, the
number of pieces that are washed off, and the reasons for the washoff. This accounting
system should help the facility identify areas where they can reduce washoff solvent usage.
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For example, if one particular piece of furniture must be washed off more than others due to
problems with the finish, the facility may be able to.identjfy^ndjconect problems operajprs
have in finishing the piece. It may be that the piece has^particularly difficult areas to finish
that may be corrected by positioning the piece differently in the spray booth. The facility
may also determine that one operator is having a relatively high number of pieces that need
to be washed off. This may be an indicator that this operator needs additional training.
The facility may also be able to determine that washoff is being used in some cases
where other methods might be successful. For example, some pieces may be able to be
sanded and then refmished rather than being washed off.
8.2.4.2 Washoff Tank. The tank used for washoff should be kept covered when it is
not in use. Some washoff tanks are quite large and the solvents are volatile. Therefore, the
tank can be a significant source of emissions. Keeping the tank covered will minimize
\yashoff solvent usage and emissions.
8.2.4.3 Operator Training. Again, proper training of operators can reduce washoff
solvent usage. Operators should be taught to keep the washoff tank covered when not in use.
They should also be taught to make sure the part is drie
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8.3.1.1 Overview of the CTG and NESHAP Requirements. While facilities do not
need to go into great detail concerning the CTG and NESHAP, operators should be given
some background information, particularly concerning requirements for which they are
ultimately responsible and the potential consequences to the facility of failing to meet those,
requirements. Operators should be given copies >of the checklists that plant inspectors will be
using to make sure the work practice standards are being followed. They will then know
what these in-house inspectors will be looking for so that if they see something they know is
a violation, for example, an open container of solvent, they can correct it. They will then
have an idea of what State inspectors will be looking for when they visit the facility.
The overview should also include a discussion Of recordkeeping requirements. In
facilities where the coatings are thinned at the spray booth, the operators will be the ones
responsible for filling out the data sheets that will be used to determine the as-applied
VOC/VHAP content of the coatings. The training program is an opportunity to show thern^
how to complete the data sheets. The operators should be shown how the information from
the data sheets is used, so that they understand the importance of making sure they are
complete and accurate.
In summary, this section of the training program should include the following:
- Background information concerning the CTG and NESHAP;
- Discussion of the work practice standards and the importance of the operator's role
in ensuring these standards are met;
- Review of any checklists the facility is planning on using to document that the work
practice standards are being implemented; and
- Overview of the recordkeeping requirements, including a presentation on how to
complete the data sheets when coatings are thinned and the importance of ensuring the data
sheets are accurate.
8.3.1.2 Training in Proper Application Techniques. Because "proper" application
technique depends upon both the type of coating and the type of application equipment, the
purpose of this section is not to provide a list of do's and dont's. The purpose is to provide
guidance on methods facilities might want to use to train operators in proper application
techniques.
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As much as possible, the program should be a hands-on training program. While
videos serve as an excellent starting point, they should be followed by hands-on training with
the application equipment.
So who should give this training? One possibility is to have the application equipment
vendor provide the training. If a facility has just switched to a different type of application
equipment, it may well be that no one at the facility has the expertise required to provide the
training. In this case, the application equipment vendor is probably the best choice. If the
facility is using the same application equipment, but has just switched from solventborne
coatings to waterborae coatings, it may want to have the coating supplier come in and assist
with the training. As discussed earlier, waterborne coatings should be applied differently
than solventborne coatings. Some facilities, particularly smaller facilities that may not be
able to obtain this service from their coating supplier and/or equipment vendor, may want to
send one person out for extensive training so that they can then come back and train the
other operators. In this case, the facility would always have someone available to train new
operators as they are hired. Smaller companies may also want to pool their resources and
have joint training sessions. Smaller facilities may also consider contacting a larger company
in their area to find out if they have regular training sessions for their operators. If they do,
the smaller facility may be able to arrange to have one of its employees sit in on one of the
sessions. This employee could then train other operators in his plant.
In summary, the following are options for providing hands-on training in proper
application techniques:
- Application equipment vendors;
- Coating suppliers, particularly if the facility has reformulated to a new type of
coating;
- Sending an employee offsite to be trained in using different types of application
equipment and different types of coatings so that person can then provide all training to the
operators onsite; and
Working with other companies to set up joint training sessions.
Make sure the hands-on training includes:
- All types of application equipment the operator will be using;
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- The application of all types of coatings the operator will be using;
- The finishing of a-variety of pieces, including pieces of tlifferent sizes and shapes. ,
It is easy to use proper application'technique when finishing a flat surface, but it is not-so
easy when finishing a chair with lots of crevices and thin slats; and
- For facilities spray applying contact adhesives, proper application techniques for
adhesives, which may be very different than for coatings.
Although refresher training is required once per year by the CTG and NESHAP,
facilities may want to have someone continue to evaluate operators throughout the year. It
is easy for anyone to slip back into bad habits. Facilities may also want to videotape
operators that are using good application techniques. The videotapes can then be used in
future training sessions.
8.3.1.3 Cleaning and Washoff Procedures. The first step in training operators in
using appropriate cleaning and washoff procedures isto familiarize them-with the work
practice standards and other elements of the pollution prevention plan that address cleaning
and washoff operations. The goal of the work practice standards and the pollution prevention
plan is to minimize cleaning and washoff solvent usage. The goals of this portion of the
training program are to help operators realize the importance of minimizing cleaning and
washoff solvent usage and the importance of the role they play.
As part of the training program, facilities should demonstrate:
- How to^clean spray guns and transfer lines;
- How to clean continuous coalers; and
- How to minimize solvent losses in the washoff process.
As discussed earlier, facilities should make sure the operators are familiar with any
checklists that have been developed, so they will know what to look for and can make
corrections as needed.
8.3.1.4 Other Information to be Included in the Training Program. Facilities may
also find it useful to include the following information in the operator training program.
(1) Facilities using an averaging approach to meet the CTG and/or NESHAP
emission limits for coatings have to keep track of their coating usage. In many cases, this
requires the operator to measure the amount of coating in a drum or tank at the beginning of
8-16
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their shift and the amount remaining at the end of the shift. Typically, this is done by
measuring the height of the coating in the drum or tank with a yardstick. While this seems
fairly straightforward, it is easy to make mistakes. In the training program, facilities should
demonstrate the correct way of measuring the amount of coating in the drum or tank in order
to minimize errors that could potentially lead to a violation of the standard.
(2) Facilities should ensure that operators know who to go to if they do have a
problem or they see a problem in another area. For example, an operator should know who
to go to if they notice their spray gun is leaking or if they are walking through the plant and
notice a leaking valve in one of the transfer lines. They are more likely to alert someone
that there is a problem if they know who they should report the problem to. They should
also know who to contact in the event of an emergency, such as a large spill.
(3) Facilities should use the training program as a forum for operators to express
ideas they may have to reduce coating or solvent usage or to make their area a safer place to
work. Facilities may also want to ask the operators what information they believe should be
included in future training programs. They are probably the best judge of what is most
useful to them.
8-17
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APPENDIX A •
ACRONYMS AND DEFINITIONS
-------
A.I LIST OF ACRONYMS
Following is a list of acronyms that are used throughout the manual. Many of Siese
terms are included in the definitions in A.2, but the list presented here is intended to serve as
a handy reference if you come across an acronym you are not familiar with. Some of these
acronyms are not used in this manual, but you may come across them when studying other
jnaterial related to the control of VOC and/or VHAP emissions.
Acronym Meaning
BACT Best available control technology
CFR Code of Federal Regulations
CPDS Certified product data sheet
CTG Control Techniques Guideline
*EPA Environmental Protection Agency
FAP Formulation assessment plan
HAP Hazardous air pollutant
HVLP High volume low pressure
LAER Lowest achievable emission rate
MACT Maximum Achievable Control Technology
MSDS Material safety data sheet
NESHAP National Emission Standards for Hazardous Air Pollutants
•NSPS New Source Performance Standards
'NSR New Source Review
RACT Reasonably Available Control Technology
SIP State implementation plan
VHAP Volatile hazardous air pollutant
VOC Volatile organic compound
A-l
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A.2 DEFINITIONS
These definitions are from the CTG model rule and the NESHAP. However, it is
not an exhaustive list. The list is limited to terms that are used in this guidance manual.
Note that these definitions are based on EPA's definitions, which may not always be
consistent with the industry's definitions. Because the standards are based on EPA's
definitions, however, those are the definitions included here.
Adhesive means any chemical substance that is applied for the purpose of bonding
two surfaces together other than by mechanical means. For the purposes of the wood
furniture NESHAP, adhesives are not considered coatings or finishing materials. Products
used on humans and animals, adhesive tape, contact paper, or any other product with an
adhesive incorporated onto or in an inert substance are not considered adhesives under the
wood furniture NESHAP.
Aerosol adhesive means a contact adhesive that is dispensed from a pressurized
container as a suspension of fine solid or liquid particles in gas.
As applied means the VOC, VHAP, and solids-content of-the .coating-or contact,
adhesive that is actually used for coating or gluing the substrate. It includes the contribution
of materials used for in-house dilution of the coating or contact adhesive.
Basecoat means a coat of colored material, usually opaque, that is applied before
graining inks, glazing coats, or other opaque finishing materials, and is usually topcoated for
protection.
Capture device means a hood, enclosed room, floor sweep, or other means of
collecting solvent emissions or other pollutants into a duct so that the pollutant can be
directed to a pollution control device such as an oxidizer or carbon adsorber.
Capture efficiency means the fraction of all organic vapors generated by a process
that are directed to a control device.
Certified product data sheet (CPDS) means documentation furnished by coating or
adhesive suppliers or an outside laboratory that provides the VHAP content, VOC content,
solids content, and density of a finishing material, contact adhesive, or solvent. The VHAP
content should be measured by EPA Method 311, an equivalent or alternative method, or
formulation data if all HAP present in the coating or contact adhesive is solvent. The
reportable VHAP content should represent the maximum aggregate emissions potential of the
finishing material, contact adhesive or solvent in concentrations greater than or equal to
1.0 percent by weight or 0.1 percent for VHAP that are carcinogens, as defined by the
Occupational Safety and Health Administration Hazard Communication Standard
(29 CFR 1910), as formulated. Only VHAP present in concentrations greater than or equal
to 1.0 percent by weight, 0.1 percent by weight for VHAP that are carcinogens, must be
reported on the CPDS. The VOC content, solids content, and density of the coating or
contact adhesive should be measured by EPA Method 24, an alternative or equivalent
A-2
-------
method, or formulation data if all of the VOC present in the coating or contact adhesive is
solvent. The purpose of the CPDS is to assist the facility in demonstrating compliance with
the CTG and/or NESHAP emission limits.
(Note: Because the optimum analytical conditions under EPA Method 311 vary by
•coating, the coating or adhesive supplier may also choose to include on the CPDS the
"optimum analytical conditions for analysis of the coating, adhesive, or solvent using EPA
Method 311. Such information may include, but not be limited to, separation column, oven
temperature, carrier gas, injection port temperature, extraction solvent, and internal
standard.)
Cleaning operations means operations in which organic solvent is used to remove
coating materials or adhesives from equipment used in wood furniture manufacturing
operations.
Coating means a protective, decorative, or functional film applied in a thin layer to a
surface. Such materials include, but are not limited to, paints, tqpcoats, varnishes, sealers,
stains, washcoats, basecoats, enamels, inks, and temporary protective coatings. Aerosol
•spray paints used for touchup and repair are not considered coatings under the under
NESHAP for Wood Furniture Manufacturing Operations.
Coating solids (or solids) means the part of the coating which remains after the
"coating is dried or cured; solids content is determined using data from EPA Method 24.
Compliant coating/contact adhesive means a finishing material, contact adhesive, or
strippable booth coating that meets the CTG and/or NESHAP emission limits specified in
^Tables 2-2 and 2-4 of this manual.
Contact adhesive means an adhesive that is applied to two substrates, dried, and
mated under only enough pressure to result in good contact. Thdfcbond is immediate and is
sufficiently strong to hold pieces together without further clamping, pressure, or airing.
Continuous coater means a finishing system that continuously applies finishing
materials onto furniture parts moving along a conveyor. Finishing materials that are not
transferred to the part are recycled to a reservoir. Several types of application methods can
be used with a continuous coater including spraying, curtain coating, roll coating, dip
coating, and flow coating.
Control device (also referred to as an add-on control device in this manual) means any
equipment that reduces the quantity of a pollutant that is emitted to the air. The device may
destroy or secure the pollutant for subsequent recovery. Includes, but is not limited to,
oxidizers, carbon adsorbers, and condensers.
Control device efficiency means the ratio of the pollution released by a control device
to the pollution introduced to the control device.
A-3
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Control system means the combination of capture and control devices used to reduce
emissions to the atmosphere.
Conventional air spray means a spray coating method in which the coating is atomized
by mixing it with compressed air and applied at an air pressure greater than 10 pounds, per
square inch'(gauge) at^he point of atomization. Airless and air assisted airless spray
technologies are not conventional air-spray because the coating is not atomized by mixing it
with compressed air. Electrostatic spray technology is also not considered conventional air
spray because an electrostatic charge is employed to attract the coating to the workpiece.
Emission means the release or discharge, whether directly or indirectly, of HAP
and/or VOC into the ambient air.
Enamel means a coat of colored material, usually opaque, that is applied as a
protective topcoat over a basecoat, primer, or previously applied enamel coats. In some
cases, another finishing material may be applied as a topcoat over the enamel.
Equipment leak means emissions of VHAP and/or VOC from pumps, valves, flanges,
or other equipment used to transfer or apply coatings, .adhesives, or organic solvents.
Finishing material means a coating used in the wood furniture industry. Such
materials include, but are not limited to, stains, basecoats, washcoats, enamels, sealers, and
topcoats.
Finishing operation means those operations in which finishing material is applied to a
substrate and is subsequently air-dried, cured in an oven, or cured by radiation.
Foam adhesive means a contact adhesive used for gluing foam to fabric, foam to
foam, and fabric to wood.
Gluine operation means those operations in which contact adhesives are used to join
components, for example, to apply a laminate to a wood substrate or foam to fabric.
Incidental wood furniture manufacturer means a major source that is primarily
engaged in the manufacture of products other than wood furniture or wood furniture
components and uses no more than 100 gallons per month of finishing material or adhesives
hi the manufacture of wood furniture or wood furniture components.
Material Safety Data Sheet (MSDS) means the documentation required for hazardous
chemicals by the Occupational Safety and Health Administration (OSHA) Hazard
Communication Standard (29 CFR 1910) for a solvent, cleaning material, contact adhesive,
coating, or other material that identifies select reportable hazardous ingredients of the
material, safety and health considerations, and handling procedures.
Nonporous substrate means a surface that is impermeable to liquids. Examples
include metal, rigid plastic, flexible vinyl, and rubber.
A-4
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Organic solvent means a volatile organic liquid that is used for dissolving or
dispersing constituents in a coating, adjusting the viscosity of a coating or adhesive, or
cleaning equipment. When used in a coating or adheawe, the organic solvent evaporatdfr
during drying and does not become a part of the dried film.
Overall control efficiency means the efficiency of a control system, calculated as the
product of the capture and control device efficiencies, expressed as a percentage.
Potential to emit means the maximum capacity of a stationary source to emit a
pollutant under its physical and operational design.
Research or laboratory facility means any stationary source whose primary purpose is
to conduct research and development to develop new processes and products where such
source is operated under the chose supervision of technically trained personnel and is not
engaged in the manufacture of products for commercial sale in commerce, except in a de
minimis manner.
Sealer means a finishing material used to seal the pores of a wood substrate before
additional coats of finishing material are applied. Special purpose finishing materials that are
used in some finishing systems to optimize aesthetics are not sealers.
Solvent means a liquid used in a coating or contact adhesive to dissolve or disperse
constituents and/or to adjust viscosity. It evaporates during drying and does not become a
part of the dried film.
Stain means any color coat having a solids content by weight of no more than
8.0 percent that is applied in single or multiple coats directly to the substrate. Includes, but
is not limited to, nongrain raising stains, equalizer stains, prestains, sap stains, body stains,
no-wipe stains, penetrating stains, and toners.
Strippable spray booth coating means a coating that (1) is applied to a spray booth
wall to provide a protective film to receive overspray during the finishing operations; (2) that
is subsequently peeled off and disposed; and (3) by achieving (1) and (2) reduces or
eliminates the need to use organic solvents to clean spray booth walls.
Substrate means the surface onto which a coating or contact adhesive is applied (or
'into which a coating or contact adhesive is impregnated).
Thinner means a volatile liquid that is used to dilute coatings or contact adhesives (to
reduce viscosity, color strength, and solids, or to modify drying conditions).
Topcoat means the last film-building finishing material that is applied in a finishing
system.
Touch-up and repair means the application of finishing materials to cover minor
finishing imperfections.
A-5
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VHAP means any hazardous air pollutant listed in Table E-l.
VHAP of potential concern means: any VHAP from me list presented in Table A-l.
Volatile organic compound (VOC) means any organic compound that participates in
atmospheric photochemical reactions, that is, any organic compound other than those that the
Administrator designates as having negligible photochemical .reactivity. A VOC may be
measured by a reference method, an equivalent method, an alternative method, or by
procedures specified in any rule. However, these methods may also measure nonreactive
organic compounds. In such cases, the owner or operator may exclude the nonreactive
organic compounds when determining compliance with a standard. For a list of compounds
that the Administrator has designated as having negligible photochemical reactivity, refer to
40CFR51.00.
Washcoat means a transparent special purpose finishing material having a solids
content by weight of 12.0 percent or less. Washcoats are applied over initial stains to
protect, to control color, -and to stiffen the wood fibers in order to aid sanding.
Washoff operations means those operations in which, organic solvent is used to
remove coating from wood furniture or a wood furniture component.
Wood furniture means any product made of wood, a wood product such as rattan or
wicker, or an engineered-wood product-such as particleboard that is manufactured under any
of the following standard industrial classification codes: 2434, 2511, 2512, 2517, 2519,
2521, 2531, 2541, 2599, or 5712.
Wood furniture component means any part that is used in the manufacture of wood
furniture. Examples include drawer sides, cabinet doors, seat cushions, and laminated tops.
Wood'furniture manufacturing operations means the finishing, gluing, cleaning, and
washoff operations associated with the production of wood furniture or wood furniture
components.
A-6
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TABLE A-1. VHAP OF POTENTIAL CONCERN
CAS No. | Chemical name
•NONTHRESHOLD- POLLUTANTS
92671
96093
64675
59892
68122
80319
60355
101779
90040
1746016
92875
684935
542881
79447
75558
57147
96128
62759
50328
1336363
76448
119937
79061
118741
57749
1120714
106990
53963
53963
58899
95807
111444
122667
8001352
121142
119904
50000
101144
107131
106934
72559
510156
4-Aminobiphenyl
Styrene oxide
Diethyl sulfate
N-Nitrosomorpholine
Dimethyl formamide
Hexamethylphosphoramide
Acetamide
4,4* -Methy lenedianiline
o-Anisidine
2,3,7,8-Tetrachlorodibenzo-p-dioxin
Benzidine
N-Nitroso-N-methylurea
Bis(chloromethyl)ether
Dimethyl carbamoyl chloride
1 ,2-Propylenimine (2-Methyl aziridine)
1,1 -Dimethyl hydrazine
1 ,2-Dibromo-3-chloropropane
N-Nitrosodimethylamine
Benzo (a) pyrene
Polychlorinated biphenyls (Arocjors)
Heptachlor
3, 3 '-Dimethyl benzidine
Acrylamide
Hexachlorobenzene
Chlordane
1,3-Propane sultone
1,3-Butadiene
2-Acetylaminoflourine
3,3' -Dichlorobenzidine
Lindane (hexachlorcyclohexane, gamma)
2,4-Toluene diamine
Dichloroethyl ether (Bis(2
-------
TABLE A-l. (continued)
CAS No.
62737
75014
75218
96457
593602
67663
87865
51796
107062
78875
56235
71432
140885
75569
62533
106467
88062
117817
95534
114261
79016
123911
75070
75252
133062
106898
75092
127184
53703
218019
60117
56553
205992
79469
542756
57976
225514
193395
189559
79345
91225
75354
Chemical name
Dichlorvos
Vinyl chloride
Ethylene oxide
Ethylene thiourea
Vinyl bromide (bromoethene)
Chloroform
Pentachlorophenol
Ethyl carbamate (Urethane)
Ethylene dichloride (1,2-Dichloroethane)
Propylene dichloride (1,2-Dichloropropane)
Carbon tetrachloride
Benzene
Ethyl acrylate
Propylene oxide
Aniline
1 ,4-Dichlorobenzene{p)
2,4,6-Trichlorophenol
Bis(2-ethylhexyl)phthalate (DEHP)
o-Toluidine
Propoxur
Trichloroethylene
1,4-Dioxane (1,4-Diethyleneoxide)
Acetaldehyde
Bromoform
Captan
Epichlorohydrin
Methylene chloride (Dichloromethane)
Tetrachloroethylene (Perchloroethylene)
Dibenz (ah) anthracene
Chrysene
Dimethyl aminoazobenzene
Benzo (a) anthracene
Benzo (b) fluoranthene
2-Nitropropane
1 ,3-Dichloropropene
7, 12-Dimethylbenz(a)anthracene
Benz(c)acridine
Indeno(l ,2,3-cd)pyrene
l,2:7,8-Dibenzopyrene
1 , 1 ,2,2-Tetrachloroethane
Quinoline
Vinyl idene chloride (1,1-Dichloroethylene)
A-8
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TABLEA-1. (continued)
CAS No.
87683
82688
78591
79005
74873
67721
1582098
1319773
108394
75343
95487
106445
74884
100425
107051
334883
95954
133904
106887
108054
126998
123319
92933
Chemical name
Hexachlorobutadiene
Pentachloronitrobenzene (Quimobenzene)
Isophorone
1,1,2-Trichloroethane
Methyl chloride (Chloromethane)
Hexachloroethane
Trifluralin
Cresols/Cresylic acid (isomers and mixture)
m-Cresol
Ethylidene dichloride (1,1-Dichloroethane)
o-Cresol
p-Cresol
Methyl iodide (lodomethane)
Styrene*
Allyl chloride
Diazomethane
2,4,5 - Trichlorophenol
Chloramben
1 ,2 Epoxybutane
Vinyl acetate
Chloroprene
Hydroquinone
4-Nitrobiphenyl
"HIGH-CONCERN" POLLUTANTS
56382
13463393
60344
75218
151564
77781
107302
57578
100447
98077
107028
584849
75741
78002
12108133
624839
77474
62207765
Parathion
Nickel Carbonyl
Methyl hydrazine
Ethylene oxide
Ethylene imine
Dimethyl sulfate
Chloromethyl methyl ether
beta-Propiolactone
Benzyl chloride
Benzo trichloride
Acrolein
2,4 - Toluene diisocyanate
Tetramethyl lead
Tetraethyl lead
Methylcyclopemadienyl manganese
Methyl isocyanate
Hexachlorocyclopentadiene
Fluomine
A-9
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TABLE A-1. (continued)
CAS No. ~
10210681
79118
534521
101688
108952
62384
98862
108316
532274
51285
108864
98953
74839
75150
121697
Chemical name
Cobalt carbonyl
Chloroacetic acid
4,6-Dinitro-o-cresol, and salts
Methylene diphenyl diisocyanate
Phenol
Mercury, (acetato-o) phenyl
Acetophenone
Maleic anhydride
2-Chloroacetophenone
2,4-Dinitrophenol
2-Methyoxy ethanol
Nitrobenzene
Methyl brpmide (Bromomethane)
Carbon disulfide
N,N-Dimethylaniline
"UNRANKABLE" POLLUTANTS
106514
123386
120809
85449
463581
132649
100027
540841
11422
822060
-
-
Quinone
Propionaldehyde
Catechol
Phthalic anhydride
Carbonyl sulfide
Dibenzofurans
4-Nitrophenol
2 , 2 ,4-Trimethy ipentane
Diethanolamine
Hexamethylene-1 ,6-diisocyanate
Glycol ethers"
Polycyclic organic matter1
* = Currently an EPA weight of evidence classification is under review
'The EPA does not currently have an official weight-of-evidence classification for
styrene. For purposes of this rule, styrene is treated as a "nonthreshold"
pollutant. (See data report form in appendix A of die hazard ranking technical
background document.)
""Except for 2-ethoxy edianol, ethylene glycol monobutyl ether, and 2-methoxy
ethanol.
'Except for benzo(b)fluoranthene, benzo(a)anthracene, benzo(a)pyrene,
7,12-dimethylbenz(a)anthracene, benz(c)acridine, chrysene, dibenz(ah)
anthracene, l,2:7,8-dibenzopyrene, indeno(l,2,3-cd)pyrene, but including dioxins
and furans.
A-10
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APPENDIX B.
LIST OF CONTACTS
-------
This appendix includes a listing of State, EPA, and industry contacts.
B.I STATE CONTACTS
Table B-l is a list of State agencies. In some cases, you may need to work with a
local agency, but the State agency will be able to refer you to the local agency if necessary.
If you are a small business, they can also refer you to the State's Small Business
Ombudsman and/or the State Small Business Assistance Program.
TABLE B-l. LISTING OF STATE AGENCIES
State
Alabama
Alaska
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Name of Agency
Alabama Department of Environmental Management, Air Division
Department of Environmental Conservation _
Office of Air Quality
Department of Pollution Control and Ecology
Air Resources Board
Department of Health, Air Pollution Control Division
Air Management Bureau
Department of Natural Resources and Environmental Control, Division of
Air and Waste Management
Department of Environmental Protection
Air Protection Branch
Clean Air Branch
Department of Health and Welfare, Division of Environmental Quality
Environmental Protection Agency, Division of Air Pollution Control
Department of Environmental Management
Department of Natural Resources
Bureau of Air and Radiation
Division for Air Quality
Department of Environmental Quality, Office of Air Quality and
Radiation Protection
Bureau of Air Quality Control, Department of Environmental Protection
Air & Radiation Management Administration
Division of Air Quality Control
Air Quality Division, Department of Natural Resources
Air Pollution Control, Pollution Control Agency
Department of Environmental Quality
Department of Natural Resources/ Air Pollution Control Program
State Department of Health and Environmental Sciences
Air Quality Program, Department of Environmental Quality
Phone No.
(205) 271-7861
(907) 465-5100
(602) 207-2308
(501) 562-7444
(916) 322-2990
(303) 692-3100
(203) 566-2690
(302) 739-4764
(904) 488-01 14
(404) 363-7000
(808) 586-4200
(208) 334-0502
(217) 782-7326
(317) 232-8222
(515) 281-5145
(913) 296-1593
(502) 564-3382
(504) 765-0219
(207) 289-2437
(410) 631-3255
(617)292-5593
(517) 373-7023
(612)296-7331
(601) 961-5171
(314) 751-4817
(406) 444-3454
(402) 471-2189
B-l
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TABLE B-l. (continued)
State
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Washington
West Virginia "
Wisconsin
Wyoming
Name of Agency
Bureau of Air Quality /Division of Environmental Protection
Department of Environmental Services, Air Resources Division
Department of Environmental Protection and Energy, Air Pollution
Control Program
Environmental Department/ Air Quality Bureau
Department of Environmental Conservation, Division of Air Resources
Division of Environmental Management
State Department of Health
Ohio Environmental Protection Agency
Department Environmental Quality/Air Quality Division
Air Quality Division, Department of Environmental Quality
Department of Environmental Resources, Bureau of Air Quality
Division of Air Resources
Department of Health and Environmental Control, Bureau of Air Quality
Department of Environment and Natural Resources, Division of
Environmental Regulation
Tennessee Division of Air Pollution Control
Texas Natural Resources Conservation Commission
Division of Air Quality, Department of Environmental Quality
Air Pollution Control Division, Agency of Natural Resources
Department of Air Pollution Control
State Department of Ecology
Air Pollution -Control Commission
Department of Natural Resources, Bureau of Air Management
Air Quality Division, Department of Environmental Quality
Phone No.
(702) 687-4670
(603) 271-1370
(609) 292-6704
(505) 827-2850
(518) 457-7230
(919) 733-3340
(701) 221-5188
(614) 644-2270
(405) 271-5220
(503) 229-5359
(717) 787-9702
(401) 277-2808
(803) 734-4750 -•
(605) 773-3351
(615) 532-0554
(512)451-5711
(801) 536-4000
(802) 244-8731
(804) 786-2378
(206) 459-6256
(304) 348-4022
(608) 266-7718
(307) 777-7391
B-2
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B.2 EPA CONTACTS
If you have questions for EPA, the best place-to start is the EPA regional office*lbr
your State. They will either be able to answer your questions or refer you to someone who
can. Table B-2 includes a list of the EPA regions, the States they cover, and their telephone
number and location.
TABLE B-2.
REGIONS
Region
1
2
3
4
5
6
7
8
9
10
Phone No.
(617) 565-2734
(212) 637-3000
(215) 566-5000
(404) 562-8357
(312) 886-6793
(214) 665-7225
(913)551-7097
(303) 293-1886
(415) 794-1143
(206) 553-1949
States covered
CT, ME, MA, NH, RI, VT
NJ, NY
DE, MD, PA, VA, WV &
District of Columbia
AL, FL, GA, KY, MS, NC,
SC, TN
IL, IN, MI, WI, MN & OH
AR, LA, NM, OK, & TX
IA, KS, MO, NE
CO, MT, ND, SD, UT, WY
AZ, CA, HI, NV
AK, ID, WA, OR
Address
Director, Air, Pesticides and Toxics Division
J.F.K. Federal Bldg.
Boston, MA 02203-22 11
Director, Air and Waste Management Div.
290 Broadway
New York, NY 10007-1866
Director, Air Management Division,
841 Chestnut Street
Philadelphia, PA 19107
Director, Air, Pesticides and Toxics Division
100 Alabama St., SW
Atlanta, GA 30303
Director, Air and Radiation Division
77 West Jackson Blvd.
Chicago, IL 60604
Director, Air, Pesticides and Toxics
1445 Ross Avenue
Dallas, TX 75202-2733
Director, Air and Toxics Division
726 Minnesota Avenue
Kansas City, KS 66101
Director, Air and Toxics Division
999 18th Streer
1 Denver Place, Suite 500
Denver, CO 80202-2405
Director, Air and Toxics Division
75 Hawthorne Street
San Francisco, CA 94105
Director, Air and Toxics Division
1200 Sixth Avenue
Seattle, WA 98101
B-3
-------
TABLE B-2. (continued)
B.3 TRADE ASSOCIATIONS
Following is a list of contacts from the major trade associations representing the wood
furniture industry and wood furniture coating suppliers.
American Furniture Manufacturers Association
P.O. Box HP-7
High Point, NC 27261
(910) 884-5000
Mr. Larry Runyan
Business and Institutional Furniture Manufacturers Association
2680 Horizon Drive S.E.
Grand Rapids, MI 49546
(616) 285-3963
Mr. Brad Miller
Kitchen Cabinet Manufacturers Association
1899 Preston White Drive
Reston, VA 22091-4326
(703) 264-1690
Mr. Dick Titus
National Paint and Coatings Association
1500 Rhode Island Avenue, NW
Washington, DC 20005
(202) 462-6272
Mr. Bob Nelson ,
B-4
-------
APPENDIX C.
OZONE NONATTAINMENT AREAS
-------
This appendix includes a listing of ozone nonattainment areas by State. While this is
the most up-to-date listing available from EPA (current as of December 3, 1996), you should
be aware that the list is always changing. For example, Shelby County: in Tennessee hits
been redesignated as an attainment area since this listing was compiled. Contact your State
or local permitting authority if you have any questions about your current
attainment/nonattainment status.
C-l
-------
Ozone Nonattafnment State/Area/County Report
Ai of October 17. 4996-
ALABAMA (Region IV)
Birmingham,
Jefferson Co
Shaky Co
ARIZONA (Region PC)
Phoenix, AZ (Moderate)
Maricopa Co (P)
Maricopa Association of
Government* Urban Planning
Area
CALIFORNIA (Region DQ _
Loa Angslee South Coa«t Air Baain,
CA (Extreme)
Lot Angalea Co (P)
Orange Co
Riverside Co (P)
San BemanSno Co (P)
Monterey Bay, CA (Moderate)
Monterey Co
SanBenttoCo
Santa Cruz Co
Sacramento Metro, CA (Severt-15)
B Dorado Co (P)
All of county up to Lake Tahoe
Placer Co (P)
AO of county up to Lake Tahoe
Sacramento Co
SolanoCo(P)
Northeastern portion
Sutler Co (P)
Southern portion
YoloCo
San Diego, CA (Serious)
San Diego Co
San Joaquln Valley, CA (Serious)
Fresno Co
Kern Co
Kings Co
MaderaCo
Merced Co
SanJoaquinCo
Stanislaus Co
TutareCo
Santa Barbara-Santa Marta-Lompoc,
CA (Moderate)
Santa Barbara Co
Southeast Desert Modified AQMA,
CA (Severe-17)
Los Angeles Co (P)
Riverside Co (P)
San Bernardino Co (P)
Ventura Co, CA (Severe-1 5*)
Ventura Co
Chlco, CA (Transitional)
ButteCo
Imperial Co, CA (TranaWonal)
Imperial Co
Yuba Ctty, CA (TranaWonal)
Sutler Co (P)
Northern porton
YubeCo
COLORADO (Region VHQ
Denver Doulder. CO (TranaWonal)
Adams Co (P)
West or iGowa Creek
Arapahoe Co (P)
West of Mows Creek
Boulder Co (P)
Excluding Rocky Mtn. National
Park
Denver Co
Douglas Co
Jefferson Co
CONNECTICLTT (Region I)
Greater Connecticut (Serious)
FairfieW Co (P)
CityofShelton
Hartford Co
LitchfieW Co (P)
All cities and townships except:
Bridgewater town
New Miiford town
Middlesex Co
New Haven Co
New London Co
TollandCo
WindhamCo
New Yortc-N. New Jersey-Long
Island, NY-HJ-CT (Severe-17)
Fairfield Co (P)
All cities and townships except
Shettoncrty
UtchfieW Co (P)
Bridgewater town
New Miiford town
DELAWARE (Region III)
PhiladelpWa-WBmington-Trerrton,
PA-NJ-DE-MD (Severe-15)
Kent Co
New Castle Co
Su**ex Co, DE (Marginal)
Sussex Co
Cherokee Co
Clayton Co
CobbCo
CowetaCo
DeKalbCo
Douglas Co
FayetteCo
ForsythCo
Fulton Co
OwinriettCo
Henry Co
PauldingCo
RockdaJeCo
ILLINOIS (Region V)
DISTRICT OF COLUMBIA (Region III)
Washington, DC-MD-VA (Serious)
Entire District
GEORGIA (Region IV)
Atlanta, GA (Serious)
Chteago-Gary-Lake County, IL-IN
(Severe-17)
Cook Co
Du Page Co
Grundy Co(P)
Aux Sable township
Goose Lake township
Kane Co
Kendall Co (P)
Oswego township
Lake Co
Me Henry Co
Will Co
St Louis, MO-4L (Moderate)
Madison Co
Monroe Co
St Clair Co
INDIANA (Region V)
Chicago-Gary-Lake County, I UN
(Severe-17)
Lake Co
Porter Co
Evanaville, IN (Marginal)
Vanderburgh Co
Louisville, KY-4N (Moderate)
Clark Co
Floyd Co
KENTUCKY (Region IV)
Cincinnati-Hamilton, OH-KY
(Moderate)
BooneCo
Campbell Co
KentonCo
Louisville, KY-IN (Moderate)
Bunmco(p)
Jefferson Co
Oldham Co (P)
LOUISIANA (Region VI)
Baton Rouge, LA (Serious)
Ascension Par
-------
Ozon0 Nonattakunent Stata/Area/County Report
AcafOotoboM?. 100C-
East Baton Rouge Par
IbervUlePar
Livingston Par
X Co
West Baton Rouge Par
Lake Chart**, LA (Marginal)
CalcasieuPar
MAINE (Region I) _
Hancock t Waldo Coa, HE (Marginal)
Hancock Co
Waldo Co
Knoa & Lincoln Coa, HE (Moderate*)
KnoxCo
Lincoln Co
(jewfston-Aubum, ME (Moderate*)
Androscoggin Co
KamebecCo
Portland, ME (Moderate)
Cumberland Co
SagadahocCo
York Co
Franklin Co, ME (Incomplete Date)
Franklin Co (P)
Oxford Co, ME (Incomplete Date)
Oxford Co (P)
Somerset Co, ME (Incomplete Date)
Somerset Co (P)
MARYLAND (Region III) _
Baltimore, MD (Severe-15)
Anne Arundel Co
Baltimore (City)
Baltimore Co
Carrofl Co
HarfbrdCo
Howard Co
Kent & Queen Aime'sCos, MD- -----
(Marginal)
Kent Co
Queen Annes Co
PNladelphla-Wllmlngton-Trenton,
PA-NJ-DE-MD (Severe-15)
Cecil Co
Washington, DC-MO-VA (Serious)
CatvertCo
ChartetCo
Frederick Co
Montgomery Co
Prince George's Co
MASSACHUSETTS (Region I) _
Boeton-Lawfwwe-Worceeter (E. MA),
MA-NH (Serious)
BamstabteCo
Bristol Co
Dukes Co
Essex Co
NantucketCo
Norfolk Co
Plymouth Co
Suffolk Co
Worcester Co
Springfield (Western MA), MA
(Serious)
BarkahiraCo
FranJdnCo
HampdanCo
HampsMraCo
MICHIGAN (Region V) _
Muekegon, M(Moderate)
MuskegonCo
Flint, M (Transitional)
Genesee Co
Allegan Co, Ml (Incomplete Date)
AUeganCo
Saginaw-Bay Ctty-MWUnd, Ml
(Incomplete Date)
Bay Co
Midland Co
SaginawCo
MISSOURI (Region VII) _
St Louis, MO-4L (Moderate)
Franklin Co
Jefferson Co
StChartesCo
St Louis
St Louis Co
NEVADA (Region IX) _
Reno, NV (Marginal)
WashoeCo
NEW HAMPSHIRE (Region I) _
Boston-Lawrence-Worcester (E. MA),
MA-NH (Serious)
Hillsborough Co (P)
Pethamtown
Amhersttown
Brookline town
Hottstown
Hudson town
LJtchfield town
Merrimack town
Milfbrdtown
Mont Vemon town
Nashua city
WiKontown
Rockingham Co (P)
Atkinson town
Brentwood town
Danville town
Deny town
E. Kingston town
HampasMdiown
Hampton Fats town
Kensington town
Kingston town
Londonderry town
Newton town
Plaistowtown
Satomtown
Sandowntown
Seabrooktown
South Hampton town
Wmdhamtown
Manchester. NH (Marginal)
Hillsborough Co (P)
Antrim town
Bedford town
Bennington town
Deeringtown
Francestown town
Goffstown town
Greenfield town
Greenville town
Hancock town
Hillsborough town
Lyndeborough town
Manchester city
Mason town
New Boston town
New Ipswich town
Peterborough town
Sharon town
Temple town
Weare town
Windsor town
Merrimack Co
Rockingham Co (P)
Auburn town
Candiatown
Chester town
DeerfieW town
Eppingtown
Fremont town
Northwood town
Nottingham town
Raymond town
Portsmouth-Oover-Rochester, NH
(Serious)
Rockingham Co (P)
Exeter town
Gn»n»andtown
Hampton town
-------
Ozone Nonattainment State/Area/County Report
••ofOrtrtm 17.1000
New Caste town
NewfieWstown
Newingtontown
* Newmarket town
' North Hampton town
Portsmouth dty
•* Rye town
'* Stiatliain town
Stranord Co
Belknap Co. NH (Incomplete Data)
DafcnapCo
Cheshire Co, NH (Incomplete Data)
ChMhiraCo
SulUvan Co, NH (Incomplete Data)
SuawanCo
NEW JERSEY (Region It)
Allerrtown-Bethlehem-Easton, PA-HJ
(Marginal)
Warren Co
Atlantic City, NJ (Moderate)
Atlantic Co
Cape May Co
New York-N. New Jersey-Long
Island, NY-NJ-CT (Severe-17)
Bergen Co
Essex Co
Hudson Co
Hunterdon Co
Middlesex Co
MonmoutrtCo
Morris Co
Ocean Co
Passaic Co
Somerset Co
Sussex Co
Unkxi Co
Philadelphia-Wllmlngton-Trenton,
PA-NJ-OE-MD (S«vere-15)
Burlington Co
CamdenCo
Cumberland Co
GtoocetterCo
Mercer Co
Salem Co
NEW MEXICO (Region VI)
Sunland Park. NM (New ATM 1995)
(Marginal)
Dona Ana Co (P)
NEW YORK (Region IQ
Albany-Schenectady-Troy, NY
(Marginal)
Albany Co
Greene Co
Montgomery Co
RenssetaerCo
Saratoga Co
Schenectady Co
Buffalo-Niagara Falls, NY (Marginal)
Erie Co
Niagara Co
[Co, NY (Marginal RT)
cCo(P)
TheporttonofWhtteface
Mountain above 4,600 feet In
etovatton In Essex County
Jefferson Co, MY (MargmaT)
JeflersonCo
New Yortc-N. New Jersey-Long
Wand, NY4U-CT (Severe-17)
Bronx Co
Kings Co
Nassau Co
New York Co
Orange Co (P)
Blooming Grove
Chester
Highlands
Monroe
Tuxedo
Warwick
Woodbury
Queens Co
Richmond Co
RoddandCo
Suffolk Co
Westcnester Co
Poughkeepale, NY (Moderate)
OutchessCo
Orange Co (P)
Remainder of County
Putnam Co
OHIO (Region V)
Cincinnati-Hamilton, OH-KY
(Moderate)
Butter Co
CtermontCo
HarrattonCo
Warren Co
OREGON (Region X)
Porttand-Vaneouver AQMA, OR-WA
(Marginal)
Clackamas Co (P)
Air Quality Maintenance Area
Muttnomah Co (P)
Air Quality Maintenance Area
Washington Co (P)
Air Quality Maintenance Area
Salem, OR (Incomplete Data)
Marion Co (P)
Salem Area TransoortaAon
Study
PofcCo(P)
Salem Area Transportation
Study
PENNSYLVANIA (Ratfon Bl)
(Marginal)
Carbon Co
LahighCo
Northampton Co
Altoona. PA (Marginal)
Blair Co
Erie. PA (Marginal)
Erie Co
rUrrisbury-Lebanon-CarttaU, P A
(Marginal)
Cumberland Co
Dauphin Co
Lebanon Co
Perry Co
Johnstown, PA (Marginal)
Cambria Co
Somerset Co
Lancaster, PA (Marginal)
Lancaster Co
Philadelphla-Wllmlngton-Trenton,
PA-NJ-OE-MO (Severe-15)
Bucks Co
Chester Co
Delaware Co
Montgomery Co
Philadelphia Co
Pttteburgh-Beaver Valley, PA
(Moderate)
Allegheny Co
Armstrong Co
Beaver Co
Butler Co
FayetteCo
Washington Co
Westmoreland Co
Reading, PA (Moderate)
Berks Co
Scranton-Wllkee-Barre, PA (MarginaT
CokjmbiaCo
LackawannaCo
LuzemeCo
Monroe Co
Wyoming Co
York, PA (Marginal)
Adams Co
York Co
Youngatown-Warran-Sharon. OtW>A
(PA Portion) (Marginal)
-------
ozone Nonanainmeru oiaiemrea/^ouniy rtepon
Mercer Co
Crawford Co. PA Oncomplete Data)
Crawford Co
Franklin Co. PA incomplete Data)
Greene Co, PA (Incomplete Date)
Greene Co
Juniate Co, PA (Incompleto Date)
Junta Co
Lawrence Co, PA (Incomplete Data)
Lawrence Co
Morthumberland Co, PA (Incomplete
Data)
Northumberland Co
POce Co, PA (Incomplete Date)
Pice Co
SchuylkUl Co, PA (Incomplete Date)
SchuytkfflCo
Snyder Co, PA (Incomplete Date)
SnyderCo
Susquehanna Co. PA (Incomplete
Date)
SusquehannaCo
Warren Co, PA (Incompleto Date)
Warren Co
Wayne Co, PA (Incomplete Date)
Wayne Co
RHODE ISLAND (Region I)
Providence (All Rl). Rl (Serious)
Bristol Co
Kent Co
Newport Co
' Providence Co
Washington Co
TENNESSEE (Region IV)
Maahvfflt, Ttl (Mederatoh
Bevkteon-Go
-Rutherford Co
Sumner Co-
Wflfiflmaon Co
BrazoriaCo
Chambers Co
Fort Bend Co
GalvestonCo
Hants Co
Liberty Co
Montgomery Co
WaOer-Co
UTAH (Region VHI)
Clark Co (P)
Air Quality Maintenance Are,
PteieeOcr
mlahOoff)
TEXAS (Region VT)
Salt Lake City, UT (Moderate)
Davis Co
Sett Lake Co
VIRGINIA (Region III)
Norfolk-Virginia Beach-Newport
News (Hampton Roade). VA
(Marginal)
Chesapeake
Hampton
James Ctty Co
Newport News
Norfolk
Poquoson
Portsmouth
Suffolk
Virginia Beach
WflBamsburg
York Co
Richmond, VA (Moderate)
Charles City Co (P)
Chesterfield Co
Colonial Heights
Hanover Co
HenricoCo
Hopewed
Richmond
.Smyth Co, VA (White Top Mtn)
(Marginal RT)
Smyth Co (P)
The portion of White Top
Mountain above 4.500 feet
elevation in Smyth county
Washington, DC-MD-VA (Serious)
Alexandria
Arlington Co
Fairfax
Fairfax Co
FaBs Church
LoudounCo
Manassas
ManassasPark
Prince WflOam Co
Stafford Co
WASHINGTON (Region X)
Portland-Vancouver AQMA, OR-WA
(Marginal)
WISCONSIN (Region V)
Door Co, Wl (Marginal RT) --
Door Co
ManKowoc Co, Wl (Moderate-]
MantowocCo
Milwaukee Racine, Wl (Severe.™
KenoshaCo '
MhvaukeeCo
CxaukeeCo
Racine Co
Washington Co
WaukeshaCo
_
Beaumont-Port Arthur, TX (Moderate)
HanfinCo
Jefferson Co
Orange Co
Dallae-Fort Worth. TX (Moderate)
Coffin Co
DaflasCo
DentonCo
TarrantCo
El faso,TX (Serious)
B Paso Co
Houston-Galveston-Brazoria, TX
(Severe-17)
Notes:
(P) : A portion of the county Is located within the area and b designated nonattainment
* : 5% classification change Sec. 1M.(a)(3)
Thb b not an official list of nonattainment areas. See the Code of Federal Register (40 CFR Part 81) and pertinent Federal Register notices for
toaal lists and boundaries.
-------
Ozorw Nonattalnm«nt Area/State/County Report
7.1000
Albany-Schenectady-Troy, NY
(Marginal)
NEW YORK (Region II)
AfeanyCo
Greene Co
Montgomery Co
RensseiaerCo
Saratoga Co
Schenectady Co
Howard Co
Baton Rouge. LA (Serious)
LOUISIANA (Region VI)
Aecencion Par
East Baton Rouge Par
ABegan Co, Ml (Incomplete Data)
MICHIGAN (Region V)
AfceganCo
Allentown-Oethlehem-Caeton. PA4U
(Marginal)
NEW JERSEY (Region II)
Warren Co
PENNSYLVANIA (Region III)
Carbon Co
LehighCo
Northampton Co
*L.
AHoona. PA (Marginal)
PENNSYLVANIA (Region III)
Blair Co
Atlanta. GA (Serious)
GEORGIA (Region IV)
Cherokee Co
Clayton-Co
CobbCo
CowetaCo
De Kalb Co
Douglas Co
Fayette Co
Forsyth Co
Fulton Co
GwinnettCo
Henry Co
PeukSngCo
RockdateCo
Atlantic City. NJ (Moderate)
NEW JERSEY (Region II)
• Atlantic Co
Cape May Co
Baltimore. MD (Severe-15)
MARYLAND (Region III)
Anne Anmdel Co
Baltimore (City)
Baltimore Co
Carroll Co
HarfordCo
Livingston Par
Pointo Coupee Par
West Baton Rouge Par
Beaumont-Port Arthur. TX (llodefata)
TEXAS (Region VI)
HanSnCo
Jefferson Co
Orange Co
Belknap Co. MH (Incomplete Data)
NEW HAMPSHIRE (Region I)
Belknap Co
Birmingham. AL (Marginal) _
ALABAMA (Region IV)
Jefferson Co
Shelby Co
Boeton-Lawrenee-Worcester (E. MA),
MA-NH (Serious)
MASSACHUSETTS (Region I)
BamstaWeCo
Bristol Co
Dukes Co
Essex Co
Middlesex Co
Nantucket Co
Norfolk Co
Plymouth Co
Suffolk Co
Worcester Co
NEW HAMPSHIRE (Region I)
Hillsborough Co (P)
Pelhamtown
Amhersttown
Brookline town
Hols town
Hudson town
Utchfieid town
Mammack town
MRford town
Mont Vemon town
Nashua city
Wilton town
Rockingham Co (P)
Atkinson town
Brentwood town
Danville town
Deny town
EL Kingston town
Hampstead£wn
Hampton Fafe town,
Kensington town
Kingston town
Londonderry town
Newton town
Ptaistowtown
Salem town
Sandowntown
Seabrooktown
South Hampton town
Windham town
Buffalo-Niagara Falts.
NEW YORK (Region 10
Erie Co
Niagara Co
Cheshire Co. NH (Incomplete Data)
NEW HAMPSHIRE (Region I)
Cheshire Co
Chlcago-Gary-Lake County, tL-IN
(Severe-17)
ILLINOIS (Region V)
Cook Co
Du Page Co
Grundy Co (P)
Aux Sable township
Goose Lake township
Kane Co
Kendall Co (P)
Oswego township
Lake Co
Me Henry Co
Will Co
INDIANA (Region V)
Lake Co
Porter Co
Chlco. CA (Tramtttenal)
CALIFORNIA (Region IX)
ButteCo
Cincinnati-Hamilton, OH-KY
(Moderate) ————
KENTUCKY (Region IV)
Boon* Co
Campbell Co
Kenton Co
OHIO (Region V)
Butter Co
Clermont Co
-------
Ozone Nonattainment Area/State/County Report
Hamflton Co
Warren Co
Crawford Co, PA (Incomplete Data)
PENNSYLVANIA (Region III)
Crawford Co
DeJws-^oft Worth, TX (Moderate)
TEXAS (Region VI)
CoMnCo
Demon Co
Tenant Co
Denver-Boulder. CO (Transitional)
COLORADO (Region VIII)
Adams Co (P)
West of Kfowa Creek
Arapahoe Co (P)
We«t of Kiowa Creek
Boulder Co (P)
Excluding Rocky Mtn. National
Park
Denver Co
Douglas Co
Jefferson Co
Door Co, Wl (Marginal RT)
WISCONSIN (Region V)
Door Co
El Paao. TX (Serious)
TEXAS (Region VI)
El Paso Co
Erie. PA (Marginal)
PENNSYLVANIA {Region III)
Erie Co
Essex Co. NY (Marginal RT)
NEW YORK (Region II)
Essex Co (P)
The portion of Whiteface
Mountain above 4.500 feet in
elevation in Essex County
EvanavWe. IN (Marginal)
INDIANA (Region V)
Vanderburgh Co
Flint. Ml (Transitional)
MICHIGAN (Region V)
GeneseeCo
Franklin Co. ME (Incomplete Data)
MAINE (Region I)
Franklin Co (P)
Franklin Co, PA (Incompleta Data)
PENNSYLVANIA (Region III)
Franklin Co
Greater ConnecBcut (Serious)
CONNECTICUT (Region 0
FaMMdCo(P)
CltyofSheton
Hartford Co
UtchMdCo(P)
Al cites and townships except
Bridgewatertown
New Mlford town
MiddtosexCo
New Haven Co
New London Co
ToUandCo
WindhamCo
Cambria Co
Somerset Co
Greene Co, PA (Incomplete Data)
PENNSYLVANIA (Region III)
Greene Co
Hancock & Waldo Coa. ME (Marginal)
MAINE (Region I)
Hancock Co
Waldo Co
Harrtsburg-Lebanon-Carilsle, PA
(Marginal)
PENNSYLVANIA (Region III)
Cumberland Co
Dauphin Co
Lebanon Co
Perry Co
Houston-Galveston-Brazoria, TX
(Severe-17)
TEXAS (Region VI)
Brazoria Co
Chambers Co
Fort Bend Co
GalvestonCo
Harris Co
Liberty Co
Montgomery Co
Waller Co
Imperial Co, CA (Transitional)
CALIFORNIA (Region IX)
Imperial Co
Jefferson Co, NY (Marginal*)
NEW YORK (Region II)
Jefferson Co
Johnstown. PA (Marginal)
PENNSYLVANIA (Region III)
Juniata Co. PA (Incompleta Daft
PENNSYLVANIA1 (Region III)
Juniata Co
Kent* Queen Anne** Cos. IIP
MARYLAND (Regton III)
Kant Co
Queen Annes Co
ttioK* Lincoln Co«. ME (Modtfii
MAINE (Region 0
KnoxCo
Lincoln Co
Lake Charles. LA (Marginal)
LOUISIANA (Region VI)
CalcasieuPar
Lancaster. PA (Marginal)
PENNSYLVANIA (Region III)
Lancaster Co
Lawrence Co, PA (Incomplett Da
PENNSYLVANIA (Region III)
Lawrence Co
Lewiston-Aubum. ME (Moderate'
MAINE (Region I)
Androscoggin Co
Kennebec Co
Los Angeles South Coast Air Bai
CA (Extreme)
CALIFORNIA (Region IX)
Los Angeles Co (P)
Orange Co
Riverside Co (P)
San Bernardino Co (P)
Louisville. KY-IN (Moderate)
INDIANA (Region V)
Clark Co
Floyd Co
KENTUCKY (Region IV)
BuHittCo(P)
Jefferson Co
OWhamCo(P)
Manchester. NH (Marginal)
NEW HAMPSHIRE (Region I)
Hillsborough Co (P)
Antrim town
Bedford town
Bennington town
-------
OZOTM Nonattainm«nt Area/Stata/County Report
tf 17. 1900
Deeringtown
Franceatown town
Coffstuwii town
Greenfield town
Greenvtte town
Hancock town
HBsborough town
Lyndeborough town
Manchester dty
Mason town
New Boston town
New Ipswich town
Peterborough town
Sharon town
Temple town
Wearetown
Wndsortown
MemmackCo
Rockingham Co (P)
Auburn town
Candiatown
Chester town
Deerfield town
Eppingtown
Fremont town
Northwood town
Nottingham town
Raymond town
Manrtowoc Co. Wl (Moderate*)
WISCONSIN (Region V)
ManrtowocCo
Milwaukee-Racine. Wl (Severe-17)
WISCONSIN (Region V)
Kenosha Co
Milwaukee Co
OzaukeeCo
Racine Co
Washington Co
WaukeshaCo
Monterey Bay. CA (Moderate)
CALIFORNIA (Region IX)
Monterey Co
SanBenttoCo
Santa Cruz Co
Miakeflon. Ml (Moderate)
MICHIGAN (Region V)
MuskegonCo
Naahvilie. TN (Moderate)
TENNESSEE (Region IV)
Davidson Co
Ruthenord Co
SumnerCb
WBamsonCo
WisonCo
MewYoifc4itl»wJef»ey4jong
bawd. MY4UCT (Sevara-17)
CONNECTICUT (Region 0
F«MWdCo(P)
Al dttes and township* except
Sheaondty
UtahMdCo(P)
BfUgewetertown
New MMord town
NEW JERSEY (Region 10
Bergen Co
Essex Co
Hudson Co
Hunteroon Co
Middlesex Co
MonmouthCo
Morris Co
Ocean Co
PassaicCo
Somerset Co
Sussex Co
-Union Co
NEW YORK (Region II)
Bronx Co
Kings Co
Nassau Co
New York Co
Orange Co (P)
Blooming Grove
Chester
Highlands
Monroe
Tuxedo
Warwick
Woodbury
Queens Co
Richmond Co
RocUandCo
SuflbftCo
WestchesterCo
NoffolkAOrginia Beach-Newport
News (Hampton Roada), VA
(Marginal)
VIRGINIA (Region 110
Chesapeake
Hampton
James City Co
Newport News
Norfolk
Poquoson
Portsmouth
Suffolk
Virginia Beach
York Co
N^tand Co. PA (kxx>mp*e>i
Data)
PENNSYLVANIA (Regjon HI)
Northumberland Co
Oxford Co. ME Qncomptota Data)
MAINE (Region 0
Oxford Co (P)
Phitadelphla-Wlmlngton-Trefiten.
PA-NJ-DE-MD (Sevwa-15)
DELAWARE (Region HO
Kent Co
New Castle Co
MARYLAND (Region III)
Cecil Co
NEW JERSEY (Region II)
Burlington Co
CamdenCo
Cumberland Co
Gloucester Co
Mercer Co
Salem Co
PENNSYLVANIA (Region 110
Bucks Co
Chester Co
Delaware Co
Montgomery Co
Philadelphia Co
Phoenix, AZ (Moderate)
ARIZONA (Region IX)
MaricopaCo(P)
Maricopa Association of
Governments Urban Planning
Area
Pike Co. PA (Incomplete Data)
PENNSYLVANIA (Region III)
Pike Co
Pittsburgh-Beaver Valley. PA
(Moderate)
PENNSYLVANIA (Region III)
Allegheny Co
Armstrong Co
-------
Ozone Nonattainment Area/State/County Report
17. 199CT
Beaver Co
Butter Co
FayetteCo
Washington Co
Washington Co
Reading, PA (Moderate)
Portland,! HE (Moderate)
MAINE (Region I)
CumbertendCo
SegedehocCo
YoifcCo
Porttond-Vincouvef AQMA. OR-WA
(Matgiml)
OREGON (Region X)
Clackamas Co (P)
Air Quatty Maintenance Area
MuMnomahCo(P)
Air QuaMy Mairttenanca Area
Washington Co (P)
Air Quality Maintenance Area-
WASHINGTON (Region X)
Clark Co (P)
Air Quality Maintenance Area
Poftemouth-Oovef-Rocheatef, NH
(Serious)
NEW HAMPSHIRE (Region I)
Rockingham Co (P)
Exeter town
Greenland town
Hampton town
New Castle town
NewfiekJs town
Newington town
Newmarket town
North Hampton town
Portsmouth city
Rye town
Stratham town
Stratford Co
Poughkeepeie, NY (Moderate-b)
NEW YORK (Region II)
DutchessCo
Orange Co (P)
Remainder of County
Putnam Co
Providence (All Rl), Rl (Serious)
RHODE ISLAND (Region 0
Bristol Co
Kent Co
Newport Co
Providence Co
PENNSYLVANIA (Region III)
Berks Co
Reno. NV (Marginal)
NEVADA (Region DQ
WashoeCo
Richmond, VA (Moderate)
VIRGINIA (Region HO
Charles City Co (P)
Chesterfield Co
Colonial Heights
Hanover Co
Henrico Co
Hopewell
Richmond
Sacramento Metro, CA (Severe-15-b)
CALIFORNIA (Region IX)
El Dorado Co (P)
All of county up to Lake Tahoe
Placer Co (P)
All of county up to Lake Tahoe
Sacramento Co
Solano Co (P)
Northeastern portion
Sutler Co (P)
Southern portion
YotoCo
Saglnaw-Bay Ctty-Midland, Ml
(Incomplete Date)
MICHIGAN (Region V)
Bay Co
Midland Co
Saginaw Co
Salem, OR (Incomplete Data)
OREGON (Region X)
Marion Co (P)
Salem Area Transportation Study
Polk Co (P)
Salem Area Transportation Study
Salt Lake City. UT (Moderate)
UTAH (Region VIII)
Davis Co
Salt Lake Co
San Diego. CA (Serious)
CALIFORNIA (Region IX)
San Diego Co
San Joaquln Valley, CA (Serious)
CALIFORNIA (Region IX)
Fresno Co
Kern Co
Kings Co
MaderaCo
Merced Co
San Joaquin Co
Stanislaus Co
TuUreCo
Santa Bariaara-Sante Maris-Lomp
CA (Moderate) "
CALIFORNIA (Region K)
Santa Bafbara Co
SchuyHdll Co, PA (Incomplete Dal
PENNSYLVANIA (Region III)
SchuyUcflICo
Scranton-Wllkea-Bane. PA (HUitf
PENNSYLVANIA (Region III)
Columbia Co
LackawannaCo
LuzemeCo
Monroe Co
Wyoming Co
Seatfle-Tacoma, WA (Marginal)
WASHINGTON (Region X)
King Co (P)
Pierce Co
Snohomish Co (P)
Smyth Co, VA (White Top Mtn)
(Marginal RT)
VIRGINIA (Region III)
Smyth Co (P)
The portion of White Top
Mountain above 4.500 feet
elevation in Smyth county
Snyder Co. PA (Incomplete Data)
PENNSYLVANIA (Region III)
Snyder Co
Somerset Co. ME (Incomplete Data
MAINE (Region 0
Somerset Co (P)
Southeaat Desert Modified AQMA.
CA (Severe-17)
CALIFORNIA (Region IX)
Los Angeles Co (P)
Riverside Co (P)
San Bernardino Co (P)
Springfield (We«i»m MAI. MA
(Seriou*)
MASSACHUSETTS (Region I)
-------
Ozone Nonattainment Area/State/County Report
AaafOotobBM?, 1QOC
Berkshire Co
Franklin Co
HampdenCo
Hampshire Co •
St Louts. MO-iL (Moderate)
UUNOIS (Region V)
Madison Co
Monroe Co
St Glair Co
MISSOURI (Region VII)
FnmUnCo
Jefferson Co
St Charles Co
St Louis
St Louis Co
Sullivan Co. NH (Incomplete Data)
NEW HAMPSHIRE (Regkxi I)
Sullivan Co
Sunland Park. NM (New Area 1995)
(Marginal)
NE^MEXICO (Region VI)
Dona Ana Co (P)
Suaquehanna Co, PA (Incomplete
Data)
PENNSYLVANIA (Region III)
Susquehanna Co
.. Suaaex Co, DE (Marginal)
DELAWARE (Region III)
Sussex Co
Ventura Co, CA (Severe-15*)
CALIFORNIA (Region IX)
Ventura Co
Warren Co. PA (Incomplete Data)
PENNSYLVANIA (Region III)
Warren Co
Washington. DO-MD-VA (Serious)
DISTRICT OF COLUMBIA (Region III)
Entire District
MARYLAND (Region III)
CaJvertCo
iChartwCo
Frederick Co
Montgomery Co
. Prince George's Co
VIRGINIA (Region III)
Alexandria
Arlington Co
Fairfax
Fairfax Co
Fads Church
LoudounCo
ManassasPark
Prince Wliam Co
Stafford Co
Wayne Co. PA Qncompleta Data)
PENNSYLVANIA (Region HO
Wayne Co
York, PA (Marginal)
PENNSYLVANIA (Region IIQ
Adam Co
York Co
Young»town-Warr»n-Sharon, OH-PA
(PA Portion) (Marginal)
PENNSYLVANIA (Region III)
Mercer Co
Yuba City. CA (Transitional)
CALIFORNIA (Region IX)
Sutler Co (P)
Northern portion
Yuba Co
Notes:
(P): A portion of the county is located within the area and is designated nonattainment.
• : 5% classification change Sec. 181.(»X3)
Tnis is not an official list of nonattainment areas. Se« the Code of Federal Register (40 CFR Part 81) and pertinent Federal Register notices for
leoal lists and boundaries
-------
Ozone Nonattainment Areas
•As of October 17.1900
Detailed Description of Certain Area Boundaries
ARIZONA
Phoenix, AZ
MaricooaCo
The Urban Planning AIM of tha Maricopa Aaaodation of Governments b bounded aa fotews:
1. Corr«r»nc»i8atapoWwhlchbattr>eWse of
Beardaley Canal, said point Is ganeraly in the northeast quarter of Section 17. Township 5 North. Range 1 East aa shown on the U.S. Geological
Survey's BaJdy Mountain. Arizona Quadrangle Map. 7.5 Minute aeries (Topographic), dated 1964;
18. thence, southwesterly and southerly along (he center fine of Beardaley Canal to a point which is the center fine of the Beardstoy Canal where it
Intersects with the center fine of Indian School Road;
19. thence, westerly along the center line of West Indian School Road to a point where the center line of West Indian School Road intersects witfi tt*
center fine of North Jacfcrabbit Trail;
20. thence, southerly along the center fine of Jacfcrabbit Trail approximately nine and three-quarter miles to a point where the center line of JacfcrabW
Trail intersects with the GiU River, said point is generally on the north-south quarter section line of Section 8, Township 1 South. Range 2 West
-------
Ozorw Nonattainment Areas
AfiofOcteby 17,1006
Detailed Description of Certain Area Boundaries
21. thence, northeasterly and easterly up fee Ota Rfcer to • potnt where the On Rtoer Intersects wthttte northern extension of the
boundary of Eatreta Mountain Regional Park, which point to gerieraeV to quarter conwr* the mrthem few of Section 31. TownaMp 1 NattX Rang*
iWest
22. thence, southerly Hong to extension of ttM western boundary and along to western boundary of Estrasa ktountata Regional Pa* to a aeM
•here to southern extension of to weetem boundary of Eatreea Mounb*R^iofi«P^MMMCli««hlh**
-------
Ozone Nonattainment Areas
AsufOuuuer IT. 1998
Detailed Description of Certain Area Boundaries
8. th^weet along the aoumbounoMaaefSeclim 13.14^5.16.17^
9. then north (long the range Im common to Range 2 EMt and Rang* 3 EMC
10.1t»nwtrf along «heto*Mhi|HMComnM^
Section 31, Township 3 Soulh. Rang* 1 West
11. then northwest along that ine to the MMMdton wtti the rang* Im conmoft eHtege 2 West and Range 1 Wast
•2. tnon north to fltit rawsUivSMi BMiMiuno County lu.
San Bernardino Co
That portion of SanBemard-io County which lee south and »eat of aKneoeecrbedasloaowa:
1. Banning at the San Baman*M - Rfcerslde County boundary and iunnlng«xth«lonfllh«wiQ«ln«ennwi»ntofUng«3EMl«r«lR«i9e2EMt,
San BenuMtfno Base and Merlolen;
2. then west along the township ana common to Township 3 North and Town»hip2N(>n1itolhaSanBamaiolno-U>«Anqale»Coun«yb()ond«y.
Sacramento Metro, CA
B Dorado Co
Al portiotw of the county ncapt that potfon of B Doraoo Oxinty wtthin M
40 CFR 81.275)
Placer Co
Alportkx* of ttw county «cep
-------
Ozone Nonattainment Areas
A«0f OctObe*47. 1096
Detaied Description of Certain Area Boundaries
9. then along the sou* boundaries of Sections 13. 14. 15. IB. 17. and 18, Township 7 North and Rang* 16 West
north along the nvxp fee commm to R*ng« 16 West and Ra^
, ,
11. then west along the ArigeJes National Foreetbourrtary to the pctt^
12. then. Met and north along iNa land grant boundary to the Loa Angatoa-Kam County boundary.
RivenrideCo _
That portion of Riverside County which tea to the east of a few described aa Mows:
ft
1. Bagbmbig at the Rfcanlda . San Oiago County boundary and running north along lha r«^ fin* cornnxxt to Rang* 4 East and Rang* 3 Eaat San
BamaroTno Baaa and Ilirlflan;
2. tan aaat along ttw towiahto fee common to Towiiehip 8 South and Township 7 South;
3. than north along tha rang* ana oornmon to Rang* 5 Eaat and Range 4 East;
4. then west along the towitshlp Ine ccmiKxt to Townehip 6 South
Range 4 East
5. than north aiong the west boundaries of Sections 34. 27. 22. 15. 10. and 3. Townthip 6 South. Range 4 East
6. than west along the township line common to Township 5 South and Township 6 South;
7. than north along the range Ina common to Range 4 Eaat and Range 3 East;
8. then west along the sooth boundaries of Sections 13. 14. 15. 16. 17. and 18. Township 5 South. Range 3 East
9. then north along the range Bne common to Range 2 East and Range 3 East
10. then west along the township line common to Township 4 South and Township 3 South to the Intersection of the southwest boundary of partial
Section 31. Township 3 South. Range 1 West
11. then northwest along that Bne to the intersection with the range line common to Range 2 West and Range 1 West
12. then north to the Riverside-San Bernardino County ine,
and that portion of Riverside County which las to the west of a Ine described as follows:
13. beginning at the northeast comer of Section 4. Township 2 South. Range 5 East a point on the boundary ine common to Riverside and San
Bernardino Counties;
14. then southerly along section lines to the cantarfne of the Colorado River Aquaduct
15. then southeasterly along the centerlne of said Colorado River Aqueduct to the southerly ine of Section 36. Township 3 South, Range 7 East
16. then easterly along the township ine to the northeast comer of Section 6. Township 4 South. Range 9 East
17. then southerly along the easterly ine of Section 6 to the southeast comer thereof;
18. then easterly along section ines to the northeast comer of Section 10, Township 4 South, Range 9 East
19. then southerly along section Ines to the southeast comer of Section 15. Township 4 South, Range 9 East
20. then easterly along the section ines to the northeast comer of Section 21 , Township 4 South, Range 10 East
21. then southerly along the easterly ine of Section 21 to the southeast comer thereof;
22. then easterly along the northerly ine of Section 27 to the northeast comer thereof;
23. then southerly along section ines to the southeast comer of Section 34, Township 4 South, Range 10 East
24. then easterly along the township ine to the northeast comer of Section 2. Township 5 South, Range 10 East
25. then southerly along the eastarty line of Section 2, to the southeast comer thereof;
26. then easteriy along the northerly ine of Section 12 to the northeast comer thereof;
27. then southerly along the range ine to the southwest comer of Section 18, Township 5 South, Range 11 East
28. then easterly along section ines to the northeast comer of Section 24, Township 5 South. Range 1 1 East
29. then southerly along the range ine to the southeast comer of Section 36. Township 8 South. Range 1 1 East a point on the boundary line
common to Riverside and San Diego Counties.
San Bernardino Co _
That portion of San Bernardino County which ies north and east of a ine described as follows:
1. Beginning at the San Bernardino - Riverside County boundary and running north along the range ine common to Range 3 East and Range 2 Eaat
San Bernardino Base and Meridian;
2. then west along the township line common to Township 3 North and Township 2 North to the San Bernardino - Los Angeles County boundary; and
that portion of San Bernardino County which lias south and west of a line described as foeows:
3. latitude 35 degrees, 10 minutes north and longitude 115 degrees. 45 minutes west
Yuba Ctty, CA
-------
Ozone Nonattainment Areas
As ef October it. 4996
Detafled Description of Certain Area Boundaries
Sutler Co
KENTUCKY
Loubvtlte, KY-IN
BufittCo ___
Thai ATM UOUndVy • M fOtOWK .Jinn Jif
Baghnlr^ at the a*jis«aon of KylOM a^ lha Ja«ai»on«u«
read 667 and the JdJenMo^us* Co«fr Ltia; piecaa^ aoutt M
proceeding to the south on Ky 1116 to the Junction win Hebron Lane; pnxa«^r«tottwso^<»HebronLanetoC«toei»^|»iii»^*^ •"«"•«
Cedar Ome* to the cor*iance of Royoa Folk lurr*ig ao«a*aMt along
ivaacaVfci»j;prooaeoTnga«ttsto^>ifraSlMpn^
across the river from Moonty
Ky 2237; proceeding south on Ky 2237 to the Junction with Ky 61 and proow»«a r^ on Ky 61 to the JUTK^ wim Ky 1494; proceed «>«h«Ky
1494tothejuncftxiwimthepernwewoftheFortKnoxMBUeryRe*er^^
Branch Road; proceeding north on <*«tteman Branch Road to Ky 44;
prooMding north on Ky 2723 to ttM Junction of CMfcoop Road; proceedins ixxtiwasicwaiiacaop Road to the juiwbon of KY26ra;pioo«OQ^ north,
on KY 2673 to lh« Junction of KY 1020; proceeding north on KY 1020 to the beutaning. unless a road or intersection of two or mow reads define* the
non«tta1nmentbound«iy;1t>earM«h»lax>»nd outward 750 fcet from the canter of the read or Intersection.
OkJhamCo _
The area boundary is a* foeows:
BeojnntogattheiritorsectionoftheOldnamJeflenw
southbound tone of Interstate 71 to the Wersection of Ky 329 end the soi/tW^nd lar* of interstate 71; proceeding to to
Meraection of Zaring Roed an Ky 329; prcceedtag to the east-northeast on Iwna Road to ffta junction of C«dar Point Road and Zadng Road;
proceeding to the north-northeast on Cedar Point Road to the junction of Ky 393 and Cedar Point Road; proceeding to the south-southeast on Ky 393
to the junction of (the access road on the north side of Reformatory Lake ani Uw Reformatory). pro<»e<^ to the east-oort^
to the jtmctton wtthvOe«rtck« Lane and the access road; proosedng to fotlcw
road 746 and DawUns Lane to the east-northeast across Ky 53 on to the U Gtangs Vi'iiur Rfration Plant proceeding on to the east-southeast along
the power line then south across Fort Pickens Road to a power substation on Ky 146. procreding along the power fine south across Ky 146 and the
Seaboard System Railroad track to adjoin the Incorporated dty limits of U Graiga; then proceeding east then south along the La Grange city into to
a point abutting the north side of Ky 71 2; proceeding east-southeast on Ky 7 U to the jundion of Massie School Road and Ky 712; proceeding to the
south-southwest on Massie School Road to the intersection of Massie School Road and Zate Smith Road; proceeding northeast on Zato Smith Road
to the junction of KY 53 and Zale Smith Road; proceeding on Ky S3 to the wjrtiwK>fthw«st to the junction of New Moody Lane and Ky S3: proceeding
on>4ew Moody Lane to ttwtoottveoathwest onty meeting the city limits of U GfSfi»s; then t^idV poweedirig rxxth fc*>wing the U Gnmge city irnte
to the intersection of the northbound lane of Interstate 71 and the La Grange dty limits; proceeding southwest on the north-bound lane of Interstate
71 until intersecting with the North Fork of Cunys Fork; proceeding south-southwest beyond the confluence of Curry* Fork to the south-southwest
beyond the confluence of Floyd* Fork continuing on to the Oldham-Jefferson County Lfoe, proceeding northwest along the Oldham-Jefferson County
Line to the beginning; unles* a road or Intersection of two or more roads defines tba ttona^ainm^flt boundary, the area shall extend outward 750 feet
from the center of the road or intersection.
MAINE
Franklin Co, ME
Franklin Co _
Avon Town. Carthage Town, Chestervtte Town. Farmington Town. Freeman Township, Industry Town. Jay Town. New Sharron
Town, New Vineyard Town, Perkins Township, PhKps Town. Salem Town&hip. Stw
-------
Ozone Nonattainment Areas
As of October 17.1306-
DetaBed Description of Certain Area Boundaries
Town. Plans Town. Peru Town. Rley Township, Roxbury Town. Roxbury Town, Rumford Town. Stoneharn Town, Stow Town. SumnarTown,
Town. VMaterloiil Town. Waat Parts Town. Woodstock Town; And BrownfteM. Denmark. Fryeburg.
rlram and Porter SM40CFR81JOmd81.78
Someraet Co, ME
SomanetCo
TMpoiloa of SomanM County which iMaoutti and «Mt of a twdMcrtMdMfotowB: Beginning at the point where the
i County boundary la Manacled by a few common to tha northern boundanM of NMPotttarriTownaMp and running northavt
M Portland, Embdan. Solon, and Athens TownaNpa to tha Intersection of said Ine wth tr» S«n-jeres*-Ptecataqi
County bouAMfy* vMGn • tfLvo oonwnofl to vw noftntMt ooffMr oi Alntnt Townwvp.)
8M40CFR81JO
NEW MEXICO
Sunland Park, NM (New Ama 1995)
Dona Ana Co
Tha ana bounded by the New Mexico-Texas State fee on the east the New Mexico- Mexico International Nne on the south, the Range 3€-Range 2£
fee on the west, and the N3200 latitude foe on the north.
VIRGINIA
Richmond, VA
Charles City Co
Beginning at the Intersection of State Road 156 and the Henricc/Chartas City County Line, proceeding south along State Route 5/156 to the
Intersection with State Route 106/156. proceeding south along Route 106/156 to the intersection with the Prince George/Chartes City County ine.
proceeding west along the Prince George/Chartes City County line to the intersection with the Chesterfield/Charles Ctty County line, proceeding north
along the Chesterfieid/Chartes City County ine to the intersection with the Henhco/Chartes City County lira, proceeding north along the
Henrico/Chartes Ctty County line to State Route 156.
WASHINGTON
Seattle-Tacoma, WA
King Co
The Mowing boundary includes sB of Pierce County, and aO of King County except a small portion on the northeast comer and the western ported of
Snohomish County:
Starting at the mouth of the Nisquatty river extend northwesterly along the Pierce County line to the southernmost point of the west county line of King
County, thence northerly along the county ine to the southernmost point of the west county line of Snohomish County; thence northerly along the
county ine to the Intersection with SR 532; thence easterly along the norm line of SR 532 to the intersection of 1-5, continuing east along the same
road now Identified as Henning Rd, to the Intersection with SR 9 at Bryant thence continuing easterly on Bryant East Rd. and Rock Creek Rd.. also
Identified as Grandview Rd., approximately 3 mies to the point at which it is crossed by the existing BPA electrical transmission ine; thence
southeasterly along the BPA transmission line approximately 8 miles to point of the crossing of the south fork of the StiFlaguamish River, thence
continuing in a south-easterly direction In a meander ine following the bed of the River to Jordan Road; southerly along Jordan Road to the north city
Imtts of Granite FaBs; thence fotowing the north and east city limits to 92nd Si N.E. and Menzel Lake Rd.: thence south-southeasterly along the
Menzel Lake Rd. and the Lake Roesiger Rd. a distance of approximately 6 mies to the northernmost point of Lake Roesiger. thence southerly along
a meander Ine fotowing the middle of the Lake ard Roesiger C^sek to Wo^
Creek approximately 6 mies to the point the Creek la crossed by the existing BPA electrics! transmission ine; thence easterly along the BPA
fcanemisalon Ine approximately 0.2 mies; thence southerly along the BPA Chief Joeeph-Covington electrical transmission Ine appragdmatefy 3 miles
to the north lr» of SR 2; thence southeasterryakxigSR 2 to ttw Inters
ine to the northernmost point of the east county ine of Pierce County, thenos akxig the county line to the poirt of begir«ing at the rnou»
Niequaty Rrvef.
Snohomish Co
The Mowing boundary includes aH of Pierce County, and an of King County except a small portion on the northeast comer and the western portion oi
Snohomish County:
Starting at the mouth of the Nwqualty river extend northwesterly along the Pierce County line to the southernmost point of the west county ine of Km
County, thence northerly along the county line to the southernmost point of the west county line of Snohomish County, thence northerly along the
county ine to the Intersection with SR 532; thence easterly along the north ine of SR 532 to the intersection of 1-5, continuing east along the t
-------
Ozone Nonattainment Areas
As of October 17. 1990
Detailed Description of Certain Area Boundaries
road now ttanttted n Honnlng Rd. to tha Maraacbon w*h SR 0 at BnnntlhtncecoriDmiingMsl^ on Biyaiit East Rd. and Rock CnokM, also
lo*ntttada«GnmdviawRd..appiQrtnata1y3mlMtothaB^rtJ^^
^MflhaaMnVtengttaBPA1nnandnioneM«ppngdma1
continuing hi a uuttVaastarty dtocbon In a maandar few 1
Imto of Granto Fait; thane* fotowlng MM north and aaat
htwUMwl M Gnmdvfew Rd.. •ppnadnuMy 3 mlM to lha point rtwhichtkcnMrtbylhcMdriingBPAobcln^
louBifcrtc of th« SUfcgu«nlrt.M»tctnon
JoMa^ •*
few falo^no Ow nt«>» etlto Ldv Md JtoMlp^CiMkto^
odnwWy 0 mtM to Vw point ttw dwk h craiMd by HM MMinQ-BPA
-------
APPENDIX D.
DETAILED TABLE OF CONTENTS FOR THE NESHAP
-------
Although we hope that this manual will answer most of the your questions concerning
the NESHAP, there may still be times when you will have to go directly to the regulation for
the answer to specific questions. Hopefully, the table of contents presented in Table D-l will
make the search easier.
TABLE D-l. NESHAP TABLE OF CONTENTS
Requirement
Location in Regulation
Applicability
Applicability of the regulation
Sources specifically exempted from the regulation
Exemption for research and laboratory facilities
List of sections of EPA's General Provisions regulation (subpart N) that apply to
sources covered under this regulation
Compliance dates for existing sources
Compliance date for new sources
Guidance for determining if source is reconstructed
63.800(a)
63.800(b)
63.800(c)
63.800(d)
63.800(e)
63.800(f)
63.800(g)
Definitions and Nomenclature
Definitions used in the regulation
Definitions of terms used in equations in the regulation
63. 801 (a)
63.801(b)
Emission Limits
Emission limits for existing sources
Emission limits for new sources
63.802(a)
63.802(b)
Work Practice Standards
Work practice implementation plan
Operator training requirements
Inspection and maintenance plan
Cleaning and washoff solvent accounting system
Chemical composition of cleaning and washoff solvents
Spray booth cleaning restrictions
Storage requirements
Application equipment requirements
Gun and line cleaning
Washoff operations
Formulation assessment plan
63. 803 (a)
63.803(b)
63.803(c)
63.803(d)
63.803(e)
63.803(0
63.803(g)
63.803(h)
63.803(i)&(j)
63.803(k)
63.803(1)
Compliance Provisions
Compliance options for finishing operations
Compliance options for gluing operations
Methods to demonstrate initial compliance
Methods to demonstrate continuous compliance
63.804(a)&(d)
63.804(b),(c) & (e)
63.804(f)
63.804(g)
D-l
-------
TABLE D-1. (continued)
Requirement
Location hi Regulation
Performance Test Methods
Test methods for determining the VHAP content of coatings and adhesives (cited
here, but actual methods will be in 40 CFR part 60, Appendix A)
Test methods for sources using control device to comply with the regulation
63.805(a)
63.805(b),(c),
(d),&(e)
Recordkeeping Requirements
Recordkeeping requirements for sources using compliant coatings and/or
averaging to comply with the regulation
Recordkeeping requirements associated with work practice standards
Recordkeeping requirements for sources using control system to ^comply with the
regulation
Miscellaneous recordkeeping requirements
63.806(b),(c) & (d)
63.806(e)
63.806(f)&(g)
63.806(h),(i)
&(j)
Reporting Requirements
Initial notification requirements
Ongoing compliance status reports
Reporting requirements for sources using a control system
Reporting requirements associated with the formulation assessment plan
63.807(b) - -..
63.807(c)
63.807(d)
63.807(e)
D-2
-------
APPENDIX E.
LIST OF VOLATILE HAZARDOUS AIR POLLUTANTS
-------
Table E-l includes a list of volatile hazardous air pollutants. The NESHAP emission
limits are based only on the VHAP content of the coatings and adhesives, not the total HAP
content. Some coatings, particularly the stains, may contain small amounts of metals that are
also VHAP, but the emission limit does not include these compounds. Therefore, the list
presented here is only for VHAP. For a listing of all 188 hazardous air pollutants, see
Section 112 of the 1990 Clean Air Act Amendments.
TABLE E-l. LIST OF VOLATILE HAZARDOUS AIR POLLUTANTS
Chemical name
Acetaldehyde
Acetamide
Acetonitrile
Acetophenone
2-Acetylaminofluorine
Acrolein
Acrylamide
Acrylic acid
Acrylonitrile
Allyl chloride
4-Aminobiphenyl
Aniline
o-Anisidine
Benzene
Benzidine
Benzotrichloride
Benzyl chloride
Biphenyl
Bis(2-ethylhexyl)phthalate (DEHP)
Bis(chloromethyl)ether
Bromoform
1,3-Butadiene
Carbon disulfide
Carbon tetrachloride
Carbonyl sulfide
Catechol
Chloroacetic acid
2-Chloroacetophenone
Chlorobenzene
Chloroform
Chloromethyl methyl ether
Chloroprene
Cresols (isomers and mixture)
o-Cresol
m-Cresol
p-Cresol
CAS No.
75070
60355
75058
98862
53963
107028
79061
79107
107131
107051
92671
62533
90040
71432
92875
98077
100447
92524
117817
542881
75252
106990
75150
56235
463581
120809
79118
532274
108907
67663
107302
126998
1319773
95487
108394
106445
E-l
-------
TABLEE-1. (continued)
Chemical name
CAS No.
Cumene
2,4-D (2,4-Dichlorophenoxyacetic acid, including salts and esters)
DDE (1, l-Dichloro-2,2-bis(p-chlorophenyl)ethylene)
Diazomethane
Dibenzofuran
1,2-Dibromo-3-chloropropane
Dibutylphthalate
1,4-Dichlorobenzene
3,3' -Dichlorobenzidine
Dichloroethyl ether (Bis(2-chloroethyl)ether)
1,3-Dichloropropene
Diethanolamine
N, N-Dimethylaniline
Diethyl sulfate
3,3' -Dimethoxybenzidine
4-Dimethylaminoazobenzene
3,3' -Dimethylbenzidine
Dimethylcarbamoyl chloride
N, N -D imethy Iformamide
1,1 -D imethy Ihydrazine
Dimethyl phthalate
Dimethyl sulfate
4,6-Dinitro-o-cresol, and salts
2,4-Dinitrophenol
2,4-Dinitrotoluene
1,4-Dioxane (1,4-Diethyleneoxide)
1,2-Diphenylhydrazine
Epichlorohydrin (l-Chloro-2,3-epoxypropane)
1,2-Epoxybutane
Ethyl acrylate
Ethylbenzene
Ethyl carbamate (Urethane)
Ethyl chloride (Chloroethane)
Ethylene dibromide (Dibromoethane)
Ethylene dichloride (1,2-Dichloroethane)
Ethylene glycol
Ethylene oxide
Ethylenethiourea
Ethylidene dichloride (1,1-Dichloroethane)
Formaldehyde
Glycol ethers
Hexachlorobenzene
Hexachloro-1,3-butadiene
Hexachloroethane
Hexamethylene-1,6-diisocyanate
98828
94757
72559
334883
132649
96128
84742
106467
91941
111444
542756
111422
121697
64675
119904
60117
119937
79447
68122
57147
131113
77781
51285
121142
123911
122667
106898
106887
140885
100414
51796
75003
106934
107062
107211
75218
96457
75343
50000
0
118741
87683
67721
822060
E-2
-------
TABLE E-l. (continued)
Chemical name
CAS No.
Hexamethylphosphoramide
Hexane
Hydrazine
Hydroquinone
Isophorone
Maleic anhydride
Methanol
Methyl bromide (Bromomethane)
Methyl chloride (Chloromethane)
Methyl chloroform (1,1,1-Trichloroethane)
Methyl ethyl ketone (2-Butanone)
Methylhydrazine
Methyl iodide (lodomethane)
Methyl isobutyl ketone (Hexone)
Methyl isocyanate
Methyl methacrylate
Methyl tert-butyl ether
4,4'-Methylenebis(2-chloroaniline)
Methylene chloride (Dichloromethane)
4,4'-Methylenediphenyl diisocyanate (MDI)
4,4'-Methy lenedianiline
Naphthalene
Nitrobenzene
4-Nitrobiphenyl
4-Nitrophenol
2-Nitropropane
N-Nitroso-N-methylurea
N-Nitrosodimethylamine
N-Nitrosomorpholine
Phenol
p-Phenylenediamine
Phosgene
Phthalic anhydride
Polychlorinated biphenyls (Aroclors)
Polycyclic Organic Matter6
1,3-Propane sultone
beta-Propiolactone
Propionaldehyde
Propoxur(Baygon)
Propylene dichloride (1,2-Dichloropropane)
Propylene oxide
1,2-Propylenimine (2-Methyl aziridine)
Quinone
Styrene
Stvrene oxide
680319
110543
302012
123319
78591
108316
67561
74839
74873
71556
78933
60344
74884
108101
624839
80626
1634044
101144
75092
101688
101779
91203
98953
92933
100027
79469
684935
62759
59892
108952
106503
75445
85449
1336363
0
1120714
57578
123386
114261
78875
75569
75558
106514
100425
96093
E-3
-------
TABLE E-1. (continued)
Chemical name
CAS No.
2,3,7,8-Tetrachlorodibenzo-p-dioxin
1,1,2,2-TetrachIoroethane
Tetrachloroethylene (Perchloroethylene)
Toluene
2,4-Toluenediamine
Toluene-2,4-diisocyanate
o-Toluidine
1,2,4-Trichlorobenzene
1,1,2-Trichloroethane
Trichloroethylene
2,4,5 -Trichlorophenol
2,4,6-Trichlorophenol
Triethylamine
Trifluralin
2,7,4 -Trimethylpentane
Vinyl acetate
Vinyl bromide
Vinyl chloride
Vinylidene chloride (1,1-Dichloroethylene)
Xylenes (isomers and mixture)
o-Xylene
m-Xylene
p-Xylene
1746016
79345
127184
108883
95807
584849
95534
120821
79005
79016
95954
88062
121448
1582098
540841
108054
593602
75014
75354
1330207
95476
108383
106423
'Includes mono- and di-ethers of ethylene glycol, diethylene glycols and triethylene
glycol; R-COCHjCHJRR-OR where: n = 1, 2, or 3; R = alkyl or aryl groups;
R' = R, H, or groups which, when removed, yield glycol ethers with the structure:
R-(OCH2CH2)n - OH. Polymers are excluded from the glycol category.
blncludes organic compounds with more than one benzene ring, and which have a boiling
point greater than or equal to 100°C.
E-4
-------
APPENDIX F.
FEDERAL REGISTER NOTICE-WOOD FURNITURE NESHAP
-------
Thursday
December 7, 1995
§ \
Part II
Environmental
Protection Agency
40 CFR Parts 9 and 63
Final Standards-for Hazardous Air
Pollutant Emissions From Wood Furniture
Manufacturing Operations; Final Rule
-------
62930 Federal Register / Vol. 60. No. 235 / Thursday, December 7, 1995 / Rules and Regulations
ENVIRONMENTAL PROTECTION
AGENCY
40CFR Part 9 and 63
(AD-FRL-5336-2)
National Emission Standards for
Hazardous Air Pollutants; Final
Standards for Hazardous Air Pollutant
Emissions From Wood Furniture
Manufacturing Operations
AGENCY: Environmental Protection
Agency (EPA).
ACTION: Final rule and test method.
SUMMARY: This final rule promulgates
standards that limit the emissions of
hazardous air pollutants (HAP) from
existing and new wood furniture
manufacturing operations located at
major sources. These final standards
implement Section 112(d) of the Clean
Air Act (CAA). as amended, which
require the Administrator to regulate
emissions of HAP listed in Section
112fb) of the CAA. The intent of the
standards is to protect the public by
requiring new and existing major
sources to control emissions to the level
attainable by implementing the
maximum achievable control
technology (MACT), taking into
consideration the cost of achieving such
emission reductions, any nonair quality
and other air quality-related health and
environmental impacts, and energy
requirements.
Many wood furniture manufacturing
facilities are major sources of HAP
emissions. Individual facilities can emit
. more than 23 megagrams per year (Mg/
yr) (25 tons per year [tons/yr]) of organic
HAP, including toluene, xylene,
methanol. methyl ethyl ketone, methyl
isobutyl ketone, glycol ethers, and
formaldehyde. All of these pollutants
can cause reversible or irreversible toxic
effects following exposure. The
potential toxic effects include eye, nose,
throat, and skin irritation and blood
cell, heart, liver, and kidney damage, as
well as reproductive effects. These
adverse health effects are associated
with a wide range of ambient
concentrations and exposure times and
are influenced by source-specific
characteristics such as emission rates
and local meteorological conditions.
Health impacts are also dependent on
multiple factors that affect human
variability such as genetics, age. health
status, (e.g.. the presence of pre-existing
disease), and lifestyle.
The EPA is also 'finalizing Method 311
with the standards. Method 311 will be
used to assist in demonstrating
compliance with the emission
limitations.
DATES: This regulation is effective
December 7.1995.
Judicial Review. Under Section
307(b)(l) of the CAA. judicial review of
national emission standards for
hazardous air pollutants (NESHAP) is
available only by filing a petition-for
review in the U.S. Court of Appeals for
the District of Columbia Circuit within
60 days of today's publication of this
final rule. Under Section 307(b)(2) of the
CAA, the requirements that are the
subject of today's notice may not be
challenged later in civil or criminal
proceedings brought by the EPA to
enforce these requirements.
ADDRESSES:
Docket: Docket No. A-93-10.
containing information, considered by
the EPA in developing the promulgated
NESHAP for wood furniture
manufacturing operations, is available
for public inspection and copying
between 8 a.m. and 5:30 p.m.. Monday
through Friday, except for Federal
holidays, at the EPA Air and Radiation
Docket and Information Center, Room
M1500, U. S. Environmental Protection
Agency. 401 M Street SW.. Washington.
DC 20460: telephone (202) 260-7548. A
reasonable fee may be charged for
copying.
Background Information Document: A
background information document (BED)
for the promulgated NESHAP may be
obtained from the docket; the U.S. EPA
Library (MD-35), Research Triangle
Park, North Carolina 27711. telephone
number (919) 541-2777; or from
National Technical Information
Services. 5285 Port Royal Road.
Springfield, Virginia 22161. telephone
(703) 487-4650. Please refer to
"National Emission Standards for
Hazardous Air Pollutants for Wood
Furniture Manufacturing Operations-
Background Information for Final
Standards" (EPA-453/R-95-018B). The
BID contains a summary of changes
made to the standards since proposal,
public comments made on the proposed
wood furniture manufacturing standard.
and the EPA responses to the comments.
Electronic versions of the
promulgation BID as well as this final
rule are available for download from the
EPA Technology Transfer Network
(TTN), a network of electronic bulletin
boards developed and operated by the
Office of Air Quality Planning and
Standards. The TTN provides
information and technology exchange in
various areas of air pollution control
The sen-ice is free, except for the cost
of a phone call. Dial (919) 541-5742 for
data transfer of up to a 14.400 bits per
second. If more information on TTN is
needed, contact the "systems operator at
(919) 541-5384.
FOR FURTH€R INFORMATION CONTACT: Mr.
Paul Almodovar of the Coatings and
Consumer Products Group, Emission
Standards Division (MD-13), U.S.
Environmental Protection Agency,
Research Triangle Park. North Carolina
27711. telephone (919) 541-0283.
SUPPLEMENTARY INFORMATION: The
information presented in this preamble
is organized as follows:
I. The Standards
II. Summary of Impacts
III. Significant Changes to the Proposed
Standards
A. Public Participation
B. Comments on the Proposed Standards
C Significant Changes
D. Other Issues
(V. Administrative Requirements
A. Docket
B. Paperwork Reduction Act
C Executive Order. 12866
D. Regulatory Flexibility Act
E. Unfunded Mandates Act
I. The Standards
The affected source for the
promulgated standards is each facility
that is engaged, either in part or in
whole, in the manufacture of wood
furniture or wood furniture components
and that is located at a plant site that is
a major source. The promulgated
standards include emission limits on
the finishing materials and contact
adhesives used by the wood furniture
industry and work practice standards to
reduce emissions from all sources of
HAP emissions. To allow owners and
operators flexibility in meeting the
emission limits, the promulgated
standards include multiple options for
complying with the limits. A summary
of the emission limits and compliance
options is presented in Table 1. A
summary of the work practice standards
is presented in Table 2.
The promulgated standards include
methods for affected sources to
demonstrate both initial and continuous
compliance with both the emission
limits and work practice standards. The
majority of affected sources will
demonstrate compliance through
recordkeeping. Affected sources that use
a control device to meet the emission
limits must monitor the performance of
the control device.
-------
; -Federal Register / Vol. 60,-No. 235 / Thursday. December 7,ii995 / Rules and Regulations 62931
TABLE 1.—SUMMAAY OF EMISSION LIMITS
Emission point
Finishing operations:
(a) Achieve a weighted average VHAP content across all coatings (maximum kg VHAP/kg solids [Ib VHAP/lb
' solids], as applied): ...
(b) Use" compliant finishing materials (maximum kg VHAP/kg solids [Ib VHAP/ttj solids], as applied);
— Stains __. _
— urq$hCQflt$ ,...„„., _.,....,. 4 .,....,,. ., . - ,. t -
—settlers
— topcoats , .,.._ .„, , ,.. '... ,.,,„ ^ „.» .„„..,,, ,., i .
— — basecoats , ,„ -
—enamels .._. .._ „ „ __
— -.e training pro-
gram snail be wntten and retained onsite.
Implementation plan | Develop a plan to implement ihese work practice stanoaros and maintain onsite.
•~->e Aorx practice standards apolv to both existing ana new major sources.
" '• • guns will be allowed only in tne following instances:
—
-------
62932
Federal Register / Vol. 60, No. 235 / Thursday. December 7. 1995 / Rules and Regulations
—touchup and repair under limited conditions;
—when spray is automated:
—when add-on controls are employed;
—if the cumulative application is less than 5 percent of the total gallons of coating applied; or
—if the permitting agency determines that it is economically or technically infeasible to use other application technologies.
Existing affected sources that emit
less than 50 tons of HAP in 1996 must
comply with the promulgated standards
by December 7.1998. Existing affected
sources that emit 50 tons or more of
HAP in 1996 must comply with the
promulgated standards by November 21.
1997. Existing area sources that become
major sources are required to comply
within one year after becoming a major
source.
New affected sources must comply
with the promulgated standards by
December 7,-1995 or upon startup.
whichever is later. New area sources
that become major sources are required
to comply with the promulgated
standards immediately upon becoming a
major source.
II. Summary of Impacts
These standards will reduce
nationwide emissions of HAP from
wood furniture manufacturing
operations by approximately 29,759 Mg/
yr (32,795 tons/yr). While the emission
limits do not require the use of lower-
VOC materials, the work practice
standards should reduce the use of VOC
containing materials and. therefore,
VOC emissions. No significant adverse
secondary air, water, solid waste, or
energy impacts are anticipated from the
promulgation of these standards.
. The implementation of this regulation
: is expected to result in nationwide
annualized costs for existing wood
furniture manufacturing operations of
S15.3 million with a cost effectiveness
of S513/Mg ($466/ton). Industry-wide
capital costs resulting from the
promulgated standards is expected to be
approximately 57.0 million.
III. Significant Changes to the Proposed
Standards
A. Public Participation
The standards were proposed in the
Federal Register on December 6, 1994
(59 FR 62652). The preamble to the
proposed standards discussed the
availability of the regulatory text. Public
comments were solicited at the time of
proposal, and copies of the regulatory
text were distributed to interested
ponies. Electronic versions of the
proposed preamble and regulation were
made available to interested parties via
the TTN (see ADDRESSES section of this
preamble).
The preamble to the proposed
standards provided the public the
opportunity to request a public hearing.
However, a public hearing was not
requested. The public comment period
for the proposed standards was
originally December 6,1994 to February
21.1995. Upon request from interested
parties the comment period on the
proposed standards was extended to
March 21.1995, and the comment
period on Method 311 was extended to
April 21.1995. In all, 50 comment
letters were received. The comments
have been carefully considered, and
changes have been made to the
proposed standards when determined
by the Administrator to be appropriate.
B. Comments on the Proposed
Standards
Comments on the proposed standards
were received from 50 commenters,
composed mainly of States, trade
organizations, coating manufacturers,
and wood furniture manufacturers. A
detailed discussion of these comments
and responses can be found in the
promulgation BED, which is referred to
in the ADDRESSES section of this
preamble. The summary of comments
and responses in the BED serve as the
basis for the revisions that have been
made to the standards between proposal
and promulgation. Most of the comment
letters contained multiple comments.
The comments have been divided into
the following areas:
1. Applicability.
2. Definitions;
3. Selection of MACT;
4. Emission limits;
5. Work practice requirements;
6. Reporting and recordkeeping
requirements;
7. Monitoring requirements;
8. Format of the standard;
9. Compliance provisions and dates;
10. Test Methods; and
11. Miscellaneous.
C. Significant Changes
Several changes have been made since
the proposal of these standards. Some of
the changes are substantive, while many
changes were made to clarify portions of
the rule that were unclear to the
commenters. A summary of the major
changes is presented below.
1. Addition of Category for Incidental
Furniture Manufacturers
The EPA received several comments
from facilities that manufacture small
quantities of furniture at their facility,
primarily for onsite use. For example, a
large laboratory facility may have a
small shop onsite for manufacturing
specialized pieces of laboratory
furniture. Many army and navy bases
have small woodworking shops onsite.
The cutoff for finishing material usage
included in the proposed standards did
not exclude these sources from the
standards, because they are major
sources due to emissions from other
operations. The majority of these
commenters indicated that they were
concerned about all of the work practio.
standards and the recordkeeping and
reporting requirements associated with
the proposed standards. They indicated
that the environmental benefit of
regulating their facilities under this
sub part would be minimal.
The promulgated standards include a
category of manufacturers known as
incidental furniture manufacturers. An
incidental furniture manufacturer is
defined in the promulgated standards a
"a major source that is primarily
engaged in the manufacture of products
other than wood furniture or wood
furniture components and that uses no
more than 100 gallons per month of
finishing material or adhesives in the
manufacture of wood furniture or wood
furniture components." Because the
promulgated standard regulates the
amount of coating these facilities can
use and still be considered incidental
furniture manufacturers, emissions froir
wood furniture manufacturing
operations at these facilities will be
minimal. The EPA agrees with the
commenters that the environmental
benefit associated with regulating these
facilities would be minimal. Therefore,
in the promulgated standards, these
facilities are exempted from the
standard. However, these facilities will
have to maintain records of coating and
adhesive usage to demonstrate they are
incidental wood furniture
manufacturers.
2. Additional Mechanism for Exempting
Smaller Sources From the Standards
The proposed standards established
applicability cutoffs based on total
material usage. Sources using no more
than 250 gallons per month, or 3.000
gallons per rolling 12-month period, of
finishing materials, adhesives. cleaning
solvents, and washoff solvents.
including materials used for operations
other than wood furniture
manufacturing, were automatically
exempted from the regulation as long as
-------
Federal Register / Vol.- 60, No. 235 / Thursday. December 7. 1995 / Rules and Regulations 62933
they maintained records demonstrating
they were below the cutoffs.
In the Anal rule, these provisions are
modified to ensure that they can serve
the purpose of exempting a facility from
the standard by limiting its potential to
emit HAP to area source levels. A
facility that otherwise would be a major
source can. at the option of the owner
or operator, become an area source
exempt from other provisions of the rule
by meeting the usage limits and
associated criteria. The usage limits
ensure that the facility's potential and
actual emissions of HAP are below the
major-source thresholds of 10 tons of a
single HAP or 25 tons of a combination
of HAP. (The EPA expects that the usage
limits will keep actual emissions from
most facilities substantially below the
major thresholds.)
To qualify as an area source under
these provisions, at least 90 percent of
annual HAP emissions from the plant
site must come from finishing materials.
adhesives. cleaning solvents, and
washoff solvents. If the plant site has
sources of HAP emissions other than
these materials, the owner or operator
must.keep any records necessary to
demonstrate that the facility meets the
90 percent criterion.
A facility may exceed the users limits
and still remain an area source exempt
from the standard if, before exceeding
the limit, the facility obtains other limits
that keep its potential to emit HAP
below the major threshold. Otherwise, a
facility that exceeds the usage limits
becomes a major source and thereafter
must comply with the standard starting
with the applicable compliance date in
the rule. These provisions prevent
facilities from vacillating between area-
source and major-source status while
evading major source requirements.
Also, these provisions make it possible
from a legal standpoint to consider the
usage cutoff levels as limiting a source's
potential to emit HAP.
The ETA also requested comment on
other mechanisms that could be used to
exempt smaller sources from the
regulation. Unless such a mechanism is
provided in the standards or by State
and local permitting authorities, many
of these smaller facilities will have to
enter the Title V permitting process in
order to obtain a Federally enforceable
limitation on their potential to emit.
This -would impose a substantial burden
on many smaller facilities and on the
State and local permitting agencies.
In response to the EPA request for
comment, several commenters indicated
that a reasonable mechanism to exempt
these sources would be to establish an
applicability cutoff based on total
emissions of HAP materials, instead of
material usage in gallons. The EPA has
included such a mechanism in the
promulgated standards, again structured
as an optional way for facilities to limit
their potential to emit. Facilities that
otherwise would be major.sources .are
considered area sources if they meet the
limits and criteria in the rule. To
qualify, a facility must use materials
containing no more than 4.5 Mg (5 tons)
of any one HAP per rolling 12-month
period or no more than 11.4 Mg (12.5
tons) of any combination of HAP per
rolling 12-month period, including
materials from source categories other
than wood furniture. Also, at least 90
percent of their plantwide emissions per
rolling 12-month period need to be
associated with the manufacture of
wood furniture or wood furniture
components. These sources need to
maintain records that demonstrate that
annual emissions do not exceed these
levels, including monthly usage records
for all finishing, gluing, cleaning, and
washoff materials: certified product data
sheets for these materials; and any other
records necessary to document
emissions from source categories other
than wood furniture.
3. Inclusion of Custom Cabinet
Manufacturers Operating Under
Standard Industrial Classification (SIC)
Code 5712 ,.
Under the proposed standards,
sources under any of nine SIC codes
were considered wood furniture
manufacturers. The SIC codes included
2434. which includes manufacturers of
kitchen cabinets. However, one
commenter pointed out that
manufacturers of custom kitchen
cabinets are included in SIC Code 5712.
The commenter felt that the operations
at these sources were not significantly
different than those operating under SIC
Code 2434 and that these sources
should also be subject to the standards.
The EPA agrees with the commenter.
and the promulgated standards include
custom kitchen cabinet manufacturers
operating under SIC Code 5712.
4. Inclusion of Definitions for Wood
Furniture and Wood Furniture
Component
Two commenters requested that the
EPA include definitions for "wood
furniture" and "wood furniture
component" in the rule. The EPA agrees
that these definitions will help clarify
which sources are subject to the rule
and has included these definitions in
the final rule.
5. Change in Title of the Formulation
Assessment Plan
Because the formulation assessment
plan only applies to VHAP of potential
concern that are present in finishing
materials, one commenter suggested that
the title be changed to formulation
assessment plan for finishing
operations. The EPA agrees that this
clarifies the scope of the formulation
assessment plan and in the final rule the
title is changed to Formulation
Assessment plan for Finishing
Operations.
6. Timeframe for Submitting Initial
Notification
Several commenters requested that
the date for submission of the initial
notification be extended. One
commenter requested that the date for
submittal of the initial notification be
extended to 270 days and two
commenters requested that the date be
extended to 180 days. The EPA agrees
with the commenters and has extended
the date for submittal of the initial
notification to 270 days after the
effective date of the final rule.
". Compliance Options
The proposed rule allowed facilities
to use one of four methods to
demonstrate compliance with the
standard: compliant coatings, averaging,
an add-on control device, or a
combination of compliant coatings and
an add-on control device. The proposed
rule did not allow facilities to use a
combination of an add-on control device
and averaging. One commenter pointed
out that this should also be a
compliance option. In some facilities.
emissions from only one or two
finishing lines will be directed to the
.control device. The emission reductions
from these lines will typically be much
greater than the reductions required for
a facility using compliant coatings.
These facilities would like to be allowed
to average these "overcontrolled"
finishing lines with uncontrolled !{*»•$-
The EPA believes this is consistent with
the regulatory negotiation agreement
and with the CAA. both of which state
that a facility should be able to use any
compliance method that they can
demonstrate achieves an equivalent
level of reductions. Therefore, the EPA
has included this compliance option in
the final rule.
8. Guidelines for Determining Capture
Efficiency
Since the wood furniture NESHAP
was proposed, the EPA has released
additional guidance on determining
capture efficiency. This guidance allows
facilities to use anv method of
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62034 Federal Register / Vol. 60. No. 235 / Thursday. December 7. 1995 / Rules and Regulations
determining the capture efficiency of a
control system as long as the data
generated from the method meets one of
two sets of criteria. These criteria are
known as the data quality objective
(DQO) approach and the lower
confidence limit (LCD approach. As one
commenter requested, this new
guidance has been included in the final
rule.
9. Clarification of Compliance Dates
Under the proposed rule, the
compliance date for sources emitting
less than SO tons of HAP per year is
three years after the effective date of the
rule. For sources emitting more than 50
tons of HAP per year, the compliance
date is November 21.1997. As one
commenter pointed out. however, the
proposed rule did not include guidance
as to which year's emissions should be
used to determine the compliance date
for a facility. In the final rule. 1996 is
identified as the baseline year for
determining a facility's compliance
date. If a facility's emissions in 1996 are
less than 50 tons of HAP then the
compliance date for that facility is
December 7, 1998. If the facility's
emissions are 50 tons of HAP or more
in 1996 then the compliance date for the
facility is November 21,1997.
10. Clarification of Definitions and
Emission Limits for Adhesives
Several commenters requested
clarification of some of the definitions
related to adhesives and also
clarification as to which adhesives are
subject to the emission limits. One
commenter indicated they did not
believe adhesives should be considered
coatings. The EPA agrees and has
changed the definition of coating so that
it no longer includes adhesives. The
definition of adhesive was also changed
to clarify that adhesives should not be
considered coatings or finishing
materials under this subpart.
Several commenters also indicated
that the rule should more accurately
reflect that contact adhesives are the
only types of adhesives that are subject
to an emission limit under this subpart.
Several changes have been made iu the
definitions. § 63.801. and in the
summary of emission limits. §63.802.
that should clarify this issue.
D. Oilier Issues
During the EPA work group review of
the final rule, two of the EPA offices
represented on the work group
indicated they had issues that they
believed needed to be addressed in the
preamble. Both EPA offices recognized
that this rule was developed under a
regulator/ negotiation approach, and
they both indicated that th«y-did not
want these issues to impact negatively
on the consensus achieved during the
regulatory negotiation. These issues are
addressed in the following paragraphs.
The EPA Office of Research and
Development (ORD) expressed concern
about the differential use of toxicity
information in the regulation. In
particular, the ORD was concerned
.about the prohibition of Class A and Bi/
B; carcinogens in cleaning and washoff
solvents. The ORD was concerned that
this prohibition implies that these
pollutants are "worse" than other HAP.
which may cause serious chronic health
effects and/or life-threatening acute
effects. Concern was also expressed that
the regulation draws a line between
pollutants with "B" and "C"
designations, when the scientific
evidence may not support such a clear
distinction. Because this regulation was
developed through a negotiation
process, ORD agreed to include this
provision in the final regulation.
However, it is important to emphasize
that the decision to include such a
provision in this specific rulemaking
does not represent a generic policy
decision on the use of weight-of-
evidence designations.
The second issue, which was raised
by the Office of Pollution Prevention
and Toxics (OPPT),.was also addressed
in the preamble to the proposed rule.
The preamble to the proposed rule
stressed that urea-formaldehyde resins,
which are used extensively in gluing
operations in the wood furniture and are
a source of formaldehyde emissions, are
not subject to an emission limit under
this regulation. During the development
of the regulation, the EPA. working *
closely with urea-formaldehyde resin
manufacturers and the wood furniture
industry, decided that it would be more
appropriate to regulate emissions from
these adhesives under the NESHAP for
plywood and particleboard
manufacturing. The OPPT has agreed
with this approach, but they indicated
that the preamble to the final rule
should reiterate the EPA intention to
regulate these adhesives under a future
rulemaking. Therefore, while the EPA is
not regulating emissions from urea-
formaldehyde resins at wood furniture
manufacturing facilities under this
rulemaking. emissions from these resins
will be regulated under the NESHAP for
plywood and particlebcard
manufacturing.
IV. Administrative Requirements
A. Dncket
The docks; is an organized and
complete file of all the information
considered by the EPA in the
development of this rule. The docket is
a dynamic file: material is added
throughout the rulemaking process. The
docketing system is intended to allow
members of the public to readily
identify and locate documents so that
they can effectively participate in the
rulemaking process. Along with the
statement of the basis and purpose of
the proposed and promulgated
standards and the EPA responses to
significant comments, the contents of
the docket will serve as the record in
case of judicial review (Section
307(d)(7)(A)].
B. Paperwork Reduction Act
The Office of Management and Budget
(OMB) has approved the information
collection requirements contained in
this rule under the provisions of the
Paperwork Reduction Act. 44 U.S.C.
3501 et seq. and has assigned OMB
control number 2060-0324.
The information required to be
collected by this rule is necessary to
identify the regulated entities who are
subject to the rule and to ensure their
compliance with the rule. The
recordkeeping and reporting
requirements are mandatory and are
being established under authority of
Section 114 of the CAA. All information
submitted to the EPA for which a claim
of confidentiality is made will be
safeguarded according to the EPA
policies set forth in Title 40. Part 2,
subpart B—Confidentiality of Business
Information.
The total annual reporting and
recordkeeping burden for this collection
averaged over the first three years is
estimated to be 140.603 hours per year.
The average burden, per respondent, is
187 hours per year. The rule requires an
initial one-time notification from each
respondent and subsequent reports/
notification would have to be submitted
semiannually. There would be an
estimated 750 respondents to the
collection requirements. This estimate
includes the time needed to review
instructions; develop, acquire, install,
and utilize technology and systems for
tKe purposes of collecting, validating.
and verifying information, processing
and maintaining information, and
disclosing and providing information:
adjust the existing ways to comply with
any previously applicable instructions
and requirements; train personnel to be
able to respond to a collection of
information: search data sources;
complete and review the collection of
information: and transmit or otherwise
disclose the information.
Send comments on the EPA need for
this information, the accuracy of the
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federal Register / Vol. 60. No. 235 / Thursday. December 7. 1995 / Rules and Regulations 62935
provided burden estimate*, and any
suggested methods for minimizing
respondent burden, including through
the use of automated collection
techniques to
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62936 Federal Register / Vol. 60. No. 235 7 Thursday. December 7,~I99r/ Rules and Regulations
Tables to Subpart IJ
Subpart JJ—National Emission
Standards for Wood Furniture
Manufacturing Operations
§ 63.300 Applicability.
[a] The affected source to which this
subpart applies is each facility that is
engaged, either in part or in whole, in
the manufacture of wood furniture or
wood furniture components and that is
located at a plant site that is a major
source as defined in 40 CFR part 63.2.
The owner or operator of a source that
meets the criteria for an incidental
furniture manufacturer shall maintain
purchase or usage records
demonstrating the source meets the
criteria specified in §63.801 of this
subpart. but the source shall not be
subject to any other provisions of this
subpart.
fb) A source that complies with the
limits and criteria specified in
paragraphs (b)(l). (b)(2). or (b)(3) of this
section is an area source for the
purposes of this subpart and is not
subject to any other provision of -this
rule, provided that: in the case of
paragraphs (b)(l) and (b)(2). finishing
materials, adhesives, cleaning solvents
and washoff solvents account for at least
90 percent of annual HAP emissions at
the plant site, and if the plant site has
HAP emissions that do not originate
from the listed materials, the owner or
operator keeps any records necessary to
demonstrate that the 90 percent
criterion is met. A source that initially
relies on the Limits and criteria specified
in paragraphs (b)(l), (b)(2). and (b}(3) to
become an area source, but
subsequently exceeds the relevant limit
(without first obtaining and complying
with other limits that keep its potential
to emit hazardous air pollutants below
major source levels), becomes a major
source and must comply thereafter with
all applicable provisions of this subpart
starting on the applicable compliance
date in § 63.800. Nothing in this
paragraph (b) is intended to preclude a
source from limiting its potential to emit
through other appropriate mechanisms
that may be available through the
permitting authority.
(1) The owner or operator of the
source uses no more than 250 gallons
per month, for every month, of coating,
gluing, cleaning, and washoff materials
at the source, including materials used
for source categories other than wood
furniture (surface coating), but
excluding materials used in routine
janitorial or facility grounds
maintenance, personal uses by
employees or other persons, the use of
products for the purpose of maintaining
motor vehicles operated by the facility.
or the use of toxic chemicals contained
in intake water (used for processing or
noncontact cooling) or intake air (used
either as compressed air or for
combustion). The owner or operator
shall maintain records of the total
gallons of coating, gluing, cleaning, and
washoff materials used each month, and
upon request submit such records to the
Administrator. These records shall be
maintained for five years.
(2) The owner or operator of the
source uses no more than 3.000 gallons
per rolling 12-month period, for every
12-month period, of coating, gluing.
cleaning, and washoff materials at the
source, including materials used for
source categories other than wood
furniture (surface coating), but
excluding materials used hi routine
janitorial or facility grounds
maintenance, personal uses by
employees or other persons, the use of
products for the purpose ol maintaining
motor vehicles operated by the facility,
or the use of toxic chemicals contained
in intake water (used for processing or
noncontact cooling) or intake air (used
either as compressed air or for
combustion). A rolling 12-month period
includes the previous 12 months of
operation. The owner or operator of the
source shall maintain records of the
total gallons of coating, gluing, cleaning,
and washoff materials used each month
and the total gallons used each previous
month, and upon request submit such
records to the Administrator. Because
records are needed over the previous set
of 12 months, the owner or operator
shall keep monthly records beginning
no less than one year before the
compliance date specified in
§ 63.800(e). Records shall be maintained
for five years.
(3) The source uses materials
containing no more than 4.5 Mg (5 tons)
of any one HAP per rolling 12-month
period or no more than 11.4 Mg (12.5
tons) of any combination of HAP per
rolling 12-month period, including
materials from source categories other
than wood furniture: and at least 90
percent of the plantwide emissions per
rolling 12-month period are associated
with the manufacture of wood furniture
or wood furniture components. The
owner or operator shall maintain
records that demonstrate that annual
emissions do not exceed these levels.
including monthly usage records for all
finishing, gluing, cleaning, and washoff
materials; certified product data sheets
for these materials: and any other
records necessary to document
emissions from source categories other
than wood furniture and upon request
submit such records to the
Administrator. These records shall be
maintained for five years.
(c) This subpart doeswiot apply to ,
research or laboratory facilities as
defined in §63.801.
(d) Owners or operators of affected
sources shall also comply with the
requirements of subpart A of this part
(General Provisions), according to the
applicability of subpart A to such
sources, as identified in Table 1 of this
subpart.
(e) The compliance date for existing
affected sources that emit less than 50
tons per year of HAP in 1996 is
December 7,1998. The compliance date
for existing affected sources that emit 50
tons or more of hazardous air pollutants
in 1996 is November 21.1997. The
owner or operator of an existing area
source that increases its emissions of (or
its potential to emit) HAP such that the
source becomes a major source that is
subject to this subpart shall comply
with this subpart one year after
becoming a major source.
(f) New affected sources must comply
with the provisions of this standard
immediately upon startup or by
December 7,1995, whichever is later.
New area sources that become major
sources shall comply with the
provisions of this standard immediately
upon becoming a major source.
(g) Reconstructed affected sources are
subject to the requirements for new
affected sources. The costs associated
with the purchase and installation of air
pollution control equipment (e.g..
incinerators, carbon adsorbers, etc.) are
not considered in determining whether
the facility has been reconstructed.
unless the control equipment is required
as part of the process (e.g.. product
recovery). Additionally, the costs of
retrofitting and replacement of
equipment that is installed specifically
to comply with this subpart are not
considered reconstruction costs. For
example, an affected source may convert
to waterbome coatings to meet the
requirements of this subpart. At most
facilities, this conversion will require
the replacement of existing storage
tanks, mix equipment, and transfer
lines. The cost of replacing the
equipment is not considered in
determining whether the facility has
been reconstructed.
§63.801 Definitions.
(a) All terms used in this subpart that
are not defined below have the meaning
given to them in the CAA and in subpart
A (General Provisions) of this pan.
Adhesive means any chemical
substance-that is applied for the purpose
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Federal^Register / Vol. 60; No. 235 / Thursday. December 7. 1995 / Rules and Regulations 62937
of bonding two surfaces together other
than by mechanical means. Under this
sub part, adhesives shall not be
considered coatings or finishing
materials. Products used on humans and
animals."adhesive tope, contact paper.
or any other product with an adhesive
incorporated onto or in an inert
substrate shall not be considered
adhesives under this subpart.
Administrator means the
Administrator of the United States
Environmental Protection Agency or his
or her authorized representative.
Aerosol adhesive means an adhesive
that is dispensed from a pressurized
container as a suspension of fine solid
or liquid particles in gas.
Affected source means a wood
furniture manufacturing facility that is
engaged, either in part or in whole, in
the manufacture of wood furniture or
wood furniture components and that is
located at a plant site that is a major
source as defined in 40 CFR part 63.2,
excluding sources that meet the criteria
established in § 63.800(a). (b) and (c) of
this subpart.
Alternative 'method means any
method of sampling and analyzing for
an air pollutant that is not a reference
or equivalent method but has been
demonstrated to the Administrator's
satisfaction to, in specific cases,
produce results adequate for a
determination of compliance.
As applied means the HAP and solids
content of the coating or contact
adhesive that is actually used for
coating or gluing the substrate. It
includes the contribution of materials
used for in-house dilution of the coating
or contact adhesive.
Basecoat means a coat of colored
material, usually opaque, that is applied
before graining inks, glazing coats, or
other opaque finishing materials, and is
usually topcoated for protection.
Baseline conditions means the
conditions that exist prior to an affected
source implementing controls, such as a
control system.
Building enclosure means a building
housing a process that meets the
requirements of a temporary total
enclosure. The EPA Method 204E is
used to identify all emission points from
the building enclosure and to determine
which emission points must be tested.
For additional information see
Guidelines for Determining Capture
Efficiency. January 1994. Docket No. A-
93-10. Item No. IV-B-1.
Capture device means a hood,
enclosed room, floor sweep, or other
means of collecting solvent emissions or
other pollutants into a duct so that the
pollutant can be directed to a pollution
control device such as an incinerator or
carbon adsorber.
Capture efficiency means the fraction
of all organic vapors generated by a
process that are directed to a control
device.
Certified product data sheet (CPDS)
means documentation furnished by
coating or adhesive suppliers or an
outside laboratory that provides the
HAP content of a finishing material.
contact adhesive, or solvent, by percent
weight, measured using the EPA
Method 311 (as promulgated in this
subpart), or an equivalent or alternative
method (or formulation data if the
coating meets the criteria specified in
§ 63.805U)); the solids content of a
finishing material or contact adhesive
by percent weight, determined using
data from the EPA Method 24, or an
alternative or equivalent method (or
formulation data if the coating meets the
criteria specified in § 63.805(a)); and the
density, measured by EPA Method 24 or
an alternative or equivalent method.
Therefore, the reportable HAP content
should represent the maximum
aggregate emissions potential of the
finishing material, adhesive, or solvent
in concentrations greater than or equal
to l.O percent by weight or 0.1 percent
for HAP that are carcinogens, as defined
by the Occupational Safety and Health
Administration Hazard Communication
Standard (29 CFR part 1910). as
formulated. The purpose of the CPDS is
to assist the affected source in
demonstrating compliance with the
emission limitations presented in
§63.802.
(Note: Because the optimum analytical
conditions under EPA Method 311 vary by
coating, the coating or adhesive supplier may
also choose to include on the CPDS the
optimum analytical conditions for analysis of
the coating, adhesive, or solvent using EPA
Method 311. Such information may include.
but not be limited to. separation column.
oven temperature, carrier gas. injection port
temperature, extraction solvent, and internal
standard.)
Cleaning operations means operations
in which organic solvent is used to
remove coating materials or adhesives
from equipment used in wood furniture
manufacturing operations.
Coating means a protective,
decorative, or functional film applied in
a thin layer to a surface. Such materials
include, but are not limited to. paints,
topcoats, varnishes, sealers, stains.
washcoats. basecoats. enamels, inks,
and temporary protective coatings.
Coating application station means the
part of a coating operation where the
coating is applied, e.g.. a spray booth.
Coating operation means those
activities in which a coating is applied
to a substrate and is subsequently air-
dried, cured in an oven, or cured by
radiation.
Coating solids (or solids) means the
part of the coating which remains after
the coating is dried or cured: solids
content is determined using'data from
the EPA Method 24, or an equivalent or
alternative method.
Compliant coating/contact adhesive
means a finishing material, contact
adhesive, or strippable booth coating
that meets the emission limits specified
in Table 3 of this subpart.
Contact adhesive means an adhesive
that is applied to two substrates, dried.
and mated under only enough pressure
to result in good contact. The bond is
immediate and sufficiently strong to
hold pieces together without further
damping, pressure, or airing.
Continuous coaler means a finishing
system that continuously applies
finishing materials onto furniture parts
moving along a conveyor. Finishing
materials that are not transferred to the
•part are recycled to a reservoir. Several
types of application methods can be
used with a continuous coaler including
spraying, curtain coating, roll coating.
dip coating, and flow coating.
Continuous compliance means that
the affected source is meeting the
emission limitations and other
requirements of the rule at all times-and
is fulfilling all monitoring and
recordkeeping provisions of the rule in
order to demonstrate compliance.
Control device means any equipment
that reduces the quantity of a pollutant
that is emitted to the air. The device
may destroy or secure the pollutant for
subsequent recovery. Includes, but is
not limited to. incinerators, carbon
•adsorbers, and condensers.
*" Control device efficiency means the
ratio of the pollutant released by a
control device and the pollutant
introduced to the control device.
Control system means the
combination of capture and control
devices used to reduce emissions to the
atmosphere.
Conventional air spray means a spray
coating method in which the coating is
atomized by mixing it with compressed
qir and applied at an air pressure greater
than 10 pounds per square inch (gauge)
at the point of atomization. Airless and
air assisted airless spray technologies
are not conventional air spray because
the coating is not atomized by mixing it
with compressed air. Electrostatic spray
technology is also not considered
conventional air spray because an
electrostatic charge is employed to
attract the coating to the workpiece.
Data quality objective (DQO)
approach means a set of approval
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62938 Federal Register / Vol. 60, No. 235 / Thursday. December 7, 1995 / Rules and Regulations
criteria that must be met-so that data
from an alternative test method can be
used in determining the capture
efficiency of a control system. For
additional information, see Guidelines
for Determining Capture Efficiency,
January 1994. (Docket No. A-93-10.
Item No. IV-B-1).
Day means a period of 24 consecutive
hours beginning at midnight local time,
or beginning at a time consistent with a
facility's operating schedule.
Disposed offsite means sending used
organic solvent.or coatings outside of
the facility boundaries for disposal.
Emission means the release or
discharge, whether directly or
indirectly, of HAP into the ambient air.
Enamel means a coat of colored
material, usually opaque, that is applied
as a protective topcoat over a basecoat,
primer, or previously applied enamel
coats. In some cases, another finishing
material may be applied as a topcoat
over the enamel.
Equipment leak means emissions of
volatile hazardous air pollutants from
pumps, valves, flanges, or other .
equipment used to transfer or apply
coatings, adhesives. or organic solvents.
Equivalent method means any method
of sampling and analyzing for an air
pollutant that has been demonstrated to
the Administrator's satisfaction to have
a consistent and quantitatively known
relationship to the reference method.
under specific conditions.
Finishing material means a coating
used in the wood furniture industry.
Such materials include, but are not
limited to, stains, basecoats, washcoats,
enamels, sealers, and topcoats.
Finishing operation means those
operations in which a finishing material
is applied to a substrate and is
subsequently air-dried, cured in an
oven, or cured by radiation.
Foam adhesive means a contact
adhesive used for gluing foam to fabric,
foam to foam, and fabric to wood.
Cluing operation means those
operations in which adhesives are used
to join components, for example, to
apply a laminate to a wood substrate or
foam to fabric.
Incidental wood furniture
manufacturer means a major source that
is primarily engaged in the manufacture
of products other than wood furniture or
wood furniture components and that
uses no more than 100 gallons per
month of finishing material or adhesives
in the manufacture of wood furniture or
wood furniture components.
Incinerator means, for the purposes of
this industry, an enclosed combustion
device that thermally oxidizes volatile
organic compounds to CO and CO;. This
term does not include devices that bum
municipal or hazardous waste material.
fanitorial maintenance means the
upkeep of equipment or building
structures that is not directly related to
the manufacturing process, for example.
cleaning of restroom facilities.
Lower confidence limit (LCL)
approach means a set of approval
criteria that must be met so that data
from an alternative test method can be
used in determining the capture
efficiency of a control system. For
additional information, see Guidelines
for Determining Capture Efficiency.
January 1994. (Docket No. A-93-10.
Item No. IV-B-1).
Material safety data sheet (MSDS)
means the documentation required for
hazardous chemicals by the
Occupational Safety and Health
Administration (OSHA) Hazard
Communication Standard (29 CFR Part
1910) for a solvent, cleaning material,
contact adhesive, coating, or other
material that identifies select reportable
hazardous ingredients of the material,
safety and health considerations, and
handling procedures.
Noncompliant coating/contact
adhesive means a finishing material,
contact adhesive, or strippable booth
coating that has a VHA? content (VOC
content for the strippable booth coating)
greater than the emission limitation
presented in Table 3 of this subpart.
Nonporous substrate means a surface
that is impermeable to liquids.
Examples include metal, rigid plastic,
flexible vinyl, and rubber.
Normally closed container means a
container that is closed unless an
operator is actively engaged in activities
such as emptying or filling the
container.
Operating parameter value means a
minimum or maximum value
established for a control device or
process parameter that, if achieved by
itself or in combination with one or
more other operating parameter values,
determines that an owner or operator
has complied with an applicable
emission limit.
Organic solvent means a volatile
organic liquid that is used for dissolving
or dispersing constituents in a coating
or contact adhesive, adjusting the
viscosity of a coating or contact
adhesive, or cleaning equipment. When
used in a coating or contact adhesive,
the organic solvent evaporates during
drying and does not become a part of
the dried film.
Overall control efficiency means the
efficiency of a control system.
calculated as the product of the capture
and control device efficiencies.
expressed as a percentage.
Permanent total enclosure means a
permanently installed enclosure that
completely surrounds a source of
emissions such that all emissions are
captured and containeoVfor-discharge
through a control device. For additional
information, see Guidelines for
Determining Capture Efficiency. January
1994. (Docket No. A-93-10. Item No.
IV-B-1). L .
Recycled onsite means the reuse of an
organic solvent in a process other than
cleaning or washoff.
Reference method means any method
of sampling and analyzing for an air
pollutant that is published in Appendix
A of 40 CFR part 60.
Research or laboratory facility means
any stationary source whose primary
purpose is to conduct research and
development to develop new processes
and products where such source is
operated under the close supervision of
technically trained personnel and is not
engaged in the manufacture of products
for commercial sale in commerce.
except in a de minimis manner.
Responsible official has the meaning
given to it in 40 CFR part 70, State
Operating Permit Programs (Title V
permits).
Sealer means a finishing material
used to seal the pores of a wood
substrate before additional coats of.
finishing material are applied. Special
purpose finishing materials that are
used in some finishing systems to
optimize aesthetics are not sealers.
Solvent means a liquid used in a
coating or contact adhesive to dissolve
or disperse constituents and/or to adjust
viscosity. It evaporates during drying
and does not become a part of the dried
film.
Stain means any color coat having a
solids content by weight of no more
than 8.0 percent that is applied in single
or multiple coats directly to the
substrate. It includes, but is not limited
to. nongrain raising stains, equalizer
stains, prestains, sap stains, body stains,
no-wipe stains, penetrating stains, and
toners.
Storage containers means vessels or
-tanks, including mix equipment, used to
hold finishing, gluing, cleaning, or
washoff materials.
Strippable spray booth material
means a coating that:
(1) Is applied to a spray booth wall to
provide a protective film to receive
overspray during finishing operations;
(2) That is subsequently peeled off
and disposed: and
(3) By achieving (1) and (2), reduces
or eliminates the need to use organic
solvents to clean spray booth walls.
Substrate means the surface onto
which a coating or contact adhesive is
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Federal Register / Vol. 60. No. 235 / Thursday. December 7, 1995 / Rules and Regulations 62939
applied (or into which a coating or
contact adhesive is impregnated).
Temporary total enclosure means an
enclosure that meets the requirements of
§63.805(e)(lHi) through (ivj.and is not
permanent, but constructed only to
measurexhe capture efficiency of
pollutants emitted from a given source.
Additionally, any exhaust point from
the enclosure shall be at least four
equivalent duct or hood diameters from
each natural draft opening. For .
additional information, see Guidelines
for Determining Capture Efficiency,
January 1994. (Docket No. A-93-10.
Item No. IV-B-1).
Thinner means a volatile liquid that is
used to dilute coatings or contact
adhesives (to reduce viscosity, color
strength, and solids, or to modify drying
conditions).
Topcoat means the last film-building
finishing material that is applied in a
finishing system.
Touchup and repair means the
application of finishing materials to
cover minor finishing imperfections.
VHAPt means any volatile hazardous
air pollutant listed in Table 2 to Subpart
JJ.
VfiAP of potential concern means any
VHAP from the nonthreshold, high
concern, or unrankable list in Table b of
this subpart.
Volatile organic compound (VOC)
means any organic compound which
participates in atmospheric
photochemical reactions, that is. any
organic compound other than those'
which the Administrator designates as
having negligible photochemical
reactivity. A VOC may be measured by
a reference method, an equivalent
method, an alternative method, or by
procedures specified under any rule. A
reference method, an equivalent
method, or an alternative method.
however, may also measure nonreactive
organic compounds. In such cases, the
owner or operator may exclude the
nonreactive organic compounds when
determining compliance with a
standard. For a list of compounds that
the Administrator has designated as
having negligible photochemical
reactivity, refer to 40 CFR part 51.10.
Washcoat means a transparent special
purpose finishing material having a
solids content by weight of 12.0 percent
by weight or less. Washcoats are applied
over initial stains to protect, to control
color, and to stiffen the wood fibers in
order to aid sanding.
Washoff operations means those
operations in which organic solvent is
used to remove coating from wood
furniture or a wood furniture
comoonent.
Wood furniture means any product
made of wood, a wood product such as
rattan or wicker, or an engineered wood
product such as particleboard that is
manufactured under any of the
following standard industrial
classification codes: 2434. 2511.2512.
2S17. 2519. 2521, 2531, 2541. 2599. or
5712.
Wood furniture component means any
pan that is used in the manufacture of
wood furniture. Examples include, but
are not limited to. drawer sides, cabinet
doors, seat cushions, and laminated
tops.
Wood furniture manufacturing
operations means the finishing, gluing.
cleaning, and washoff operations
associated with the production of wood
furniture or wood furniture
components.
(b) The nomenclature used in this
subpart has the following meaning:
(1) Ak = the area of each natural draft
opening (k) in a total enclosure, in
square meters.
(2) Ce=the VHAP content of a
finishing material (c). in kilograms of
volatile hazardous air pollutants per
kilogram of coating solids (kg VHAP/kg
solids), as supplied. Also given in
pounds of volatile hazardous air
pollutants per pound of coating solids
(Ib VHAP/lb solids).
(3) C,,=the concentration of VHAP in
gas stream (j) exiting the control device.
in parts pei*million by volume.
(4) C«,i=the concentration of VHAP in
gas stream (i) entering the control
device, in parts per million by volume.
(5) Coi=the concentration of VHAP in
gas stream (i) entering the control device
from the affected source, in parts per
million by volume.
(6) Crv=the concentration of VHAP in
uncontrolled gas stream (k) emitted
directly to the atmosphere from the
affected source, in parts per million by
volume.
(7) E=the emission limit achieved by
an emission point or a set of emission
points, in kg VHAP/kg solids (Ib VHAP/
Ib solids).
(8) F=the control device efficiency,
expressed as a fraction.
(9) FV=the average inward face
velocity across all natural draft openings
in a total enclosure, in meters per hour.
(10) G=the VHAP content of a contact
adhesive, in kg VHAP/kg solids Ob
VHAP/lb solids), as applied.
(11) M=the mass of solids in finishing
material used monthly, kg solids/month
(Ib solids/month).
(12) N=the capture efficiency,
expressed as a fraction.
(13) Q»j=the volumetric flow rate of
gas stream (j) exiting the control device.
in dry standard cubic meters per hour.
(14) Qj,,=the volumetric flow rat* of
gas stream (i) entering the control
device, in dry standard cubic meters per
hour.
(15) Qo,=the volumetric flow rate of
gas stream (i) entering the control device
from the emission point, in dry standard
cubic meters per hour.
(16) Q/v=the volumetric flow rate of
uncontrolled gas stream (k) emitted
directly to the atmosphere from the
emission point, in dry standard cubic
meters per hour.
(17) Qjn j=the volumetric flow rate of
gas stream (i) entering the total
enclosure through a forced makeup air
duct, in standard cubic meters per hour
(wet basis).
(18) Qow j=the volumetric flow rate of
gas stream (j) exiting the total enclosure
through an exhaust duct or hood, in
standard cubic meters per hour (wet
basis).
(19) R=the overall efficiency of the
control system, expressed as a
percentage.
(20) S=the VHAP content of a solvent.
expressed as a weight fraction, added to
finishing materials.
(21) W=the amount of solvent, in
kilograms (pounds), added to finishing
materials during the monthly averaging
period.
(22) ac=after the control system is
installed and operated.
(23) bc=before control.
§ 63.802 Emission limits.
(a) Each owner or operator of an
existing affected source subject to this
subpart shall:
(1) Limit VHAP emissions from
finishing operations by meeting the
emission limitations for existing sources
presented in Table 3 of this subpart.
using any of the compliance methods in
§ 63.804(a). To determine VHAP
emissions from a finishing material
containing formaldehyde or styrene, the
owner or operator of the affected source
shall use the methods presented in
§ 63.803(1)(2) for determining styrene
and formaldehyde usage.
(2) Limit VHAP emissions from
contact adhesives by achieving a VHAP
limit for contact adhesives based on the
following criteria:
(i) For foam adhesives (contact
adhesives used for upholstery
operations) used in products"that meet
the upholstered seating flammability
requirements of California Technical
Bulletin 116.117. or 133. the Business
and Institutional Furniture
Manufacturers Association's (BffMA's)
X5.7. UFAC flammability testing, or any
similar requirements from local. State.
or Federal fire regulatory agencies, the
VHAP content of the adhesive shall not
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62940 Federal Register / Vol. 60. No. 235 / Thursday. December 7. 1995 / Rules and Regulations
exceed 1.8 leg VHAP/kg solids (1.8 Ib
VHAP/lb solids), as applied; or
(ii) For all other contact adhesives
(including foam adhesives used in
products that do not meet the standards
presented in paragraph (a)(2)(i) of this
section, but excluding aerosol adhesives
and excluding contact adhesives
applied to nonporous substrates, the
VHAP content of the adhesive shall not
exceed 1.0 kg VHAP/kg solids (1.0 Ib
VHAP/lb solids), as applied.
(3) Limit HAP emissions from
strippable spray booth coatings by using
coatings that contain no more than 0.8
kg VOC/kg solids (0.8 Ib VOC/lb solids).
as applied.
(b) Each owner or operator of a new
affected source subject to this subpart
shall:
(l) Limit VHAP emissions from
finishing operations by meeting the
emission limitations for new sources
presented in Table 3 of this subpart
using any of the compliance methods in
§ 63.804('d). To determine VHAP
emissions from a finishing material
containing formaldehyde or styrene. the
owner or operator of the affected source
shall use the methods presented in
§ 63.803(11(2) for determining styrene
and formaldehyde usage.
(2) Limit VHAP emissions from
contact adhesives by achieving a VHAP
limit for contact adhesives, excluding
aerosol adhesives and excluding contact
adhesives applied to nonporous
substrates, of no greater than 0.2 kg
VHAP/kg solids (0.2 Ib VHAP/lb solids).
as applied, using either of the
compliance methods in §63.804(e).
(3) Limit HAP emissions from
strippable spray booth coatings by using
coatings that contain no more than 0.8
kg VOC/kg solids (0.8 Ib VOC/lb solids).
as applied.
§ 60.303 Work practice standards.
(a) Work practice implementation
plan. Each owner or operator of an
affected source subject to this subpart
shall prepare and maintain a written
work practice implementation plan that
defines environmentally desirable work
practices for each wood furniture
manufacturing operation and addresses
each of the work practice standards
presented in paragraphs (b) through (1)
of this section. Tlie plan shall be
developed no more than 60 days after
the compliance date. The written work
practice implementation plan shall be
available for inspection by the
Administrator upon request. If the
Administrator determines that the work
practice implementation plan does not
adequately address each of the topics
specified in paragraphs (b) through (1) of
this section or that the plan does not
include sufficient mechanisms for
ensuring that the work practice
standards are being implemented, the
Administrator may require the affected
source to modify the plan. Revisions or
modifications to the plan do not require
a revision of the source's Title V permit.
(b) Operator training course. Each
owner or operator of an affected source
shall train all new and existing
personnel, including contract personnel.
who are involved in finishing, gluing.
cleaning, and wasboff operations, use of
manufacturing equipment, or
implementation of the requirements of
this subpart All new personnel, those
hired after the compliance date of the
standard, shall be trained upon hiring.
All existing personnel, those hired
before the compliance date of the
standard, shall be trained within six
months of the compliance date of the
standard,. All personnel shall be given
refresher training annually. The affected
source shall maintain a copy of the
training program with the work practice
implementation plan. The training
program shall include, at a minimum,
the following:
(1) A list of all current personnel by
name and job description that are
required to be trained:
. (2) An outline of the subjects to be
covered in the initial and refresher
training for each position or group of
personnel;
(3) Lesson plans for courses to be
given at the initial and the annual
refresher training that include, at a
minimum, appropriate application
techniques, appropriate cleaning and
washoff procedures, appropriate
equipment setup and adjustment to
minimize finishing material usage and
overspray, and appropriate management
of cleanup wastes: and
(4) A description of the methods to be
used at the completion of initial or
refresher training to demonstrate and
document successful completion.
(c) Inspection and maintenance plan.
Each owner or operator of an affected
source shall prepare and maintain with
the work practice implementation plan
a written leak inspection and
maintenance plan that specifies:
(1) A minimum visual inspection
frequency of once per month for all
equipment used to transfer or apply
coatings, adhesives, or organic solvents;
(2) An inspection schedule:
(3) Methods for documenting the date
and results of each inspection and any
repairs that were made;
(4) The timeframe between identifying
the leak and making the repair, which
adheres, at a minimum, to the following
schedule:
(i) A first attempt at repair (e.g..
tightening of packing glands) shall be
made no later than five calendar days
after the leak is detected? and
(ii) Final repairs shall be made within
15 calendar days after the leak is
detected, unless the leaking equipment
is to be replaced by a new purchase, in
which case repairs shall be completed
within three months.
(d) Cleaning and washoff solvent
accounting system. Each owner or
operator of an affected source shall
develop an organic solvent accounting
form to record:
(1) The quantity and type of organic
solvent used each month for washoff
and cleaning, as defined in § 63.801 of
this subpart;
(2) The number of pieces washed off,
and the reason for the washoff; and
(3) The quantity of spent solvent
generated from each washoff and
cleaning operation each month, and
whether it is recycled onsite or disposed
offsite.
(e) Chemical composition of cleaning
and washoff solvents.£ach owner or
operator of an affected source shall not
use cleaning or washoff solvents that
contain any of the pollutants listed in
Table 4 to this subpart, in
concentrations subject to MSDS
reporting as required by. OSHA.
(f) Spray booth cleaning. Each owner
or operator of an affected source shall
not use compounds containing more
than 8.0 percent by weight of VOC for
cleaning spray booth components other
than conveyors, continuous coalers and
their enclosures, or metal filters, unless
the spray booth is being refurbished. If
the spray booth is being refurbished.
that is the spray booth coating or other
protective material used to cover the
booth is being replaced, the affected
source shall use no more than 1.0 gallon
of organic solvent per booth to prepare
the surface of the booth prior to
applying the booth coating.
fcg) Storage requirements. Each owner
or operator of an affected source shall
use normally closed containers for
storing finishing, gluing, cleaning, and
washoff materials.
(h) Application equipment
requirements. Each owner or operator of
an affected source shall use
conventional air spray guns to apply
finishing materials only under any of
the following circumstances:
(1) To apply finishing materials that
have a VOC content no greater than 1.0
Ib VOC/lb solids, as applied:
(2) For touchup ana repair under the
following conditions:
(i) The touchup and repair occurs
after completion of the finishing
operation: or
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Federal Register-/ Vol. 60. No. 235 / Thursday. December 7,.1995 / Rules and Regulations 62941
(ii) The touchup and repair occurs
after the application of stain and before
the application of any other type of
finishing material, and the materials
used for touchup and repair are applied
from a container that has a volume of no
more then 2.0 gallons.
(3) Wfcen spray is automated, that is,
the spray gun is aimed and triggered
automatically, not manually:
(4) When emissions from the finishing
application station are directed to a
control device:
(5) Tbt conventional air gun is used
to apply finishing materials and the
cumulative total usage of that finishing
material is no more-than 5.0 percent of
the total gallons of finishing material
used daring that semiannual period; or
(6) Tire conventional air gun is used
to apply stain on a part for which it is
technieilly or economically infeasible to
use any other spray application
technology.
The effected source shall demonstrate
technical or economic infeasibility by
submitting to the Administrator a
videotape, a technical report, or other
documentation that supports the
affected source's claim of technical or
economic infeasibility. The following
criteria shall be used, either
independently or in combination, to
support the affected source's claim of
technical or economic infeasibilitv:
(i) Tie production speed is too high
or the part shape is too complex for one
operator to coat the pan and the
application station is not large enough
to accommodate an additional operator:
or
(ii) The excessively large vertical
spray area of the part makes it difficult
to avoid sagging or runs in the stain.
(i) line cleaning. Each owner or
operator of an affected source shall
pump or drain all organic solvent used
for liae cleaning into a normally closed
container.
(j) Can cleaning. Each owner or
operator of an affected source shall
colled all organic solvent used to dean
spray guns into a normally closed
container.
(k) Washoff operations. Each owner or
operator of an affected source shall
control emissions from washoff
operations by:
(1) Using normally dosed tanks for
washoff: and
(2} Minimizing dripping by tilting or
rotating the part to drain as much
solvent as possible.
(1) Formulation assessment plan for
finishing operations. Each owner or
operator of an affected source shall
prepare and maintain with the work
practice implementation plan a
formulation assessment plan that:
(1) Identifies VHAP from the list
presented in Table 5 of this subpart that
are being used in finishing operations
by the affected source:
(2) Establishes a baseline level of .,
usage by the affected source, for each
VHAP identified in paragraph (l)(l) of '
this section. The baseline usage level
shall be the highest annual usage from
1994.199S. or 1996. for each VHAP
identified in paragraph (1)(1) of this
section. For formaldehyde, the baseline
level of usage shall be based on the
amount of free formaldehyde present in
the finishing material when it is
applied. For styrene, the baseline level
of usage shall be an estimate of
unreacted styrene, which shall be
calculated by multiplying the amount of
styrene monomer in the finishing
material, when it is applied, by a factor
of 0.16. Sources using a control-device
to reduce emissions may adjust their
usage based x>n the overall control
efficiency of the control system, which
is determined using the equation in
§ 63.805 (d) or (e).
(3) Tracks the annual usage of each
VHAP identified in (1)(1) by the affected
source that is present in amounts
subject to MSDS reporting as required
by OSHA.
(4) If, after November 1998, the
annual usage of the VHAP identified in
paragraph (1)(1) exceeds its baseline
level, then the owner or operator of the
affected source shall provide a written
notification to the permitting authority
that describes the amount of the
increase and explains the reasons for
exceedance of the baseline level. The
following explanations would relieve
the owner or operator from further
action, unless the affected source is not
in compliance with any State
regulations or requirements for that
VHAP:
(i) The exceedance is no more than
15.0 percent above the baseline level:
(ii) Usage of the VHAP is below the
de minimis level presented in Table 5
of this subpart for that VHAP (sources
using a control device to reduce
emissions may adjust their usage based
on the overall control efficiency of the
control system, which is determined
using the procedures in § 63.805 (d) or
(e);
(iii) The affected source is in
compliance with its State's air toxic
regulations or guidelines for the VHAP:
or
(iv) The source of the pollutant is a
finishing material with a VOC content of
no more than 1.0 kg VOC/kg solids (1.0
Ib VOC/lb solids), as applied.
(5) If none of the above explanations
are the reason for the increase, the
owner or operator shall confer with the
permitting authority to discuss the
reason for the increase and whether
there are practical and reasonable
technology-based solutions for reducing
the usage. The evaluation of whether a
technology is reasonable and^practical
shall be based on cost, quality, and
marketability of the product, whether
the technology is being used
successfully by other wood furniture
manufacturing operations, or other
criteria mutually agreed upon by the
permitting authority and owner or
operator. If there are no practical and
reasonable solutions, the fadlity need
take no further action. If there are
solutions, the owner or operator shall
develop a plan to reduce usage of the
pollutant to the extent feasible. The plan
shall address the approach to be used to
reduce emissions, a timetable for
implementing the plan, and a schedule
for submitting notification of progress.
(6) If after November 1998. an affected
source uses a VHAP of potential
concern for which a baseline level has
not been previously established, then
the baseline level shall be established as
the de minimis level, based on 70 year
exposure levels and data provided in
the proposed rulemaking pursuant to
Section 112(g) of the CAA, for that
pollutant. A list of VHAP of potential
concern is provided in Table 6 of this
subpart. If usage of the VHAP of
potential concern exceeds the de
minimis level, then the affected source
shall provide an explanation to the
permitting authority that documents the
reason for exceedance of the de minimis
level. If the explanation is not one of
those listed in paragraphs (l)(4)(i)
through (l)(4)(iv), the affected source
shall follow the procedures established
~
§ 63.804 Compliance procedures and
monitoring requirements.
(a) The owner or operator of an
existing affected source subject to
§ 63.802(a)(l) shall comply with those
provisions using any of the methods
presented in §63.804 (a)(l) through
(a)(4).
(1) Calculate the average VHAP
content for all finishing materials used
at the facility using Equation. 1, and
maintain a value of E no greater than
1.0;
E=(Mc,C:l + McjCe: * • ' ' + McnCcn *
S,W, + S7W: * • • • SnWn)/f.M
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62942 Federal. Register / Vol. 60. No. 235 / Thursday. December 7, 1995 / Rules and Regulations
§63.802 (a)(l) or (b)(l) that comply
through the procedures established in
§ 63.804 (a)(2) or (d)(2) shall submit an
initial compliance status report, as
required by § 63.807(b). stating that
compliant stains, washcoats. sealers;
topcoats, basecoats, enamels, and
thinners. as applicable, are being used
by the affected source.
(3) Owners or operators of an affected
source subject to the provisions of
§ 63.802 (a)(l) or (b)(l) that are
complying through the procedures
established in § 63.804 (a)(2) or (d)(2)
and are applying coatings using
continuous coalers shalj demonstrate
initial compliance by:
(i) Submitting an initial compliance
status report, as required by § 63.807(b).
stating that compliant coatings, as
determined by the VHAP content of the
coating in the reservoir and the VHAP
content as calculated from records, and
compliant thinners are being used: or
(ii) Submitting an initial compliance
status report, as required by § 63.807(b).
stating that compliant coatings, as
determined by the VHAP content of the
coating in the reservoir, are being used;
the viscosity of the coating in the
reservoir is being monitored: and
compliant thinners are being used. The
affected source shall also submit data
that demonstrate that viscosity is an
appropriate parameter for demonstrating
compl'iance.
(4) Owners or operators of an affected
source subject to the provisions of
§ 63.802 (a)(l) or (b)(l) that comply
through the procedures established in
§ 63.804 (a)(3) or (d)(3) shall
demonstrate initial compliance by:
4i) Submitting a monitoring plan that
identifies each operating parameter to
be monitored for the capture device and
discusses why each parameter is
appropriate for demonstrating
continuous compliance;
(ii) Conducting an initial performance
test as required under § 63.7 using the
procedures and test methods listed in
§ 63.7 and § 63.805 (cl and (d) or (e);
(iii) Calculating the overall control
efficiency (R) following the procedures
in § 63.805 (d) or (e); and
(iv) Determining those operating
conditions critical to determining
compliance and establishing one or
more operating parameters that will
ensure compliance with the standard.
(A) For compliance with a thermal
incinerator, minimum combustion
temperature shall be the operating
parameter.
(B) For compliance with a catalytic
incinerator equipped with a fixed"
catalyst bed. the minimum gas
temperature both upstream and
porcent VHAP by weight by maintaining
certified product data sheets for each
coating and thinner:
(ii) Demonstrate that each washcoat.
hasecoat. and enamel that is purchased
pre-made. that is, it is not formulated
onsite by thinning another finishing
material, has a VHAP content of no
more than 1.0 kg VHAP/kg solids (1.0 Ib
VHAP/lb solids), as applied, and each
thinner contains no more than 10.0
percent VHAP by weight by maintaining
certified product data sheets for each
coating and thinner; and
(iii) Demonstrate that each washcoat.
basecoat. and enamel that is formulated
at the affected source is formulated
using a finishing material containing no
more than 1.0 kg VHAP/kg solids (1.0 Ib
VHAP/lb solids) and a thinner
containing no more than 3.0 percent
VHAP by weight.
(3) Use a control system with an
overall control efficiency (R) such that
the value of EK in Equation 2 is no
greater than 1.0.
R=i(Ebc-EK)/EBcl(100) Equation 2
The value of £« in Equation 2 shall
be calculated using Equation 1; or
(4) Use any combination of an
averaging approach, as described in
paragraph (a)(l) of this section.
compliant finishing materials, as
described in paragraph (a)(2) of this
section, and a control system, as
described in paragraph (a)(3) of this
section.
(b) The owner or operator of an
affected source subject to
§ 63.802(a)(2)(i) shall comply with the
provisions by using compliant foam
adhesives with a VHAP content no
greater than 1.8 kg VHAP/kg solids (1.8
Ib VHAP/lb solids), as applied.
(c) The owner or operator of an
affected source subject to
§ 63.802(a)(2)(ii) shall comply with
those provisions by using either of the
methods presented in § 63.804. (c)(l) and
(0(2).
(1) Use compliant contact adhesives
with a VHAP content no greater than 1.0
kg VHAP/kg solids (1.0 Ib VHAP/lb
solids), as applied: or
(2) Use a control system with an
overall control efficiency (R) such that
the value of Gx is no greater than 1.0.
R=[(Gbc - GaJ/Gbc] (100) Equation 3
(d) The owner or operator of a new
affected source subject to § 63.802(b)(l)
may comply with those provisions by
using any of the following methods:
(1) Calculate the average VHAP
content across all finishing materials
used at the facility using Equation 1,
and maintain a value of E no greater
than 0.8:
(2) Use compliant finishing materials
according to the following criteria:
(i) Demonstrate that each sealer and
topcoat has a VHAP content of no more
than 0.8 kg VHAP/kg solids (0.8 Ib
VHAP/lb solids], as applied, each stain
has a VHAP content of no more than 1.0
kg VHAP/kg solids (1.0 Ib VHAP/lb
solids), as applied, and each thinner
contains no more than 10.0 percent
VHAP by weight:
(ii) Demonstrate that each washcoat.
basecoat. and enamel that is purchased
pre-made. that is. it is not formulated
onsite by thinning another finishing
material, has a VHAP content of no
more than 0.8 kg VHAP/kg solids (0.8 Ib
VHAP/lb solids), as applied, and each
thinner contains no more than 10.0
percent VHAP by weight: and
(iii) Demonstrate that each washcoat.
basecoat. and enamel that is formulated
onsite is formulated using a finishing
material containing no more than 0.8 kg
VHAP/kg solids (0.8 Ib VHAP/lb solids)
and a thinner containing no more than
3.0 percent HAP by weight.
(3) Use a control system with an
overall control efficiency (R) such that
the value .of E* in Equation 4 is no
greater than 0.8.
R=[(Ebc - EaJ/EftcKlOO) Equation 4
The value of £« in Equation 4 shall
be calculated using Equation 1: or
(4) Use any combination of an
averaging approach, as described in
(d)(l), compliant finishing materials, as
described in (d)(2), and a control
system, as described in (d)(3).
(e) The owner or operator of a new
affected source subject to § 63.802(b)(2)
shall comply with the provisions using
either of the following methods:
(l) Use compliant contact adhesives
with a VHAP content no greater than 0.2
kg VHAP/kg solids (0.2 Ib VHAP/lb
solids), as applied: or
(2) Use a control system with an
overall control efficiency (R) such that
the value of GK in Equation 3 is no
greater than 0.2.
(f) Initial compliance. (1) Owners or
operators of an affected source subject to
the provisions of § 63.802 (a)(l) or fb)(l)
that comply through the procedures
established in § 63.804 (a')(l) or (d)(l)
shall submit the results of the averaging
calculation (Equation 1) for the first
month with the initial compliance
status report required by § 63.807(b).
The first month's calculation shall
include data for the entire month in
which the compliance date falls. For
example, if the source's compliance date
is November 21.1997. the averaging
calculation shall include data from
November 1, 1997 to November 30,
1997.
(2) Owners or operators of an affected
source subject to :he provisions of
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Federal.Register / Vol. 60. No. 235 / Thursday. December 7. 1995 / Rules and Regulations 62943
downstream of the catalyst bed .shall be
the operating parameter.
(C) For compliance with a catalytic
incinerator equipped with a fluidized
catalystbed.Hhe minimum gas
temperature upstream of the catalyst
bed and the pressure drop across the
catalyst bed shall be the operating
parameters.
(D) For compliance with a carbon
adsorber, the operating parameters shall
be the total regeneration mass stream
flow for each regeneration cycle and the
carbon bed temperature after each
regeneration, or the concentration level
of organic compounds exiting the
adsorber, unless the owner or operator
requests and receives approval from the
Administrator to establish other
operating parameters.
(E) For compliance with a control
device not listed in this section, one or
more operating parameter values shall
be established using the procedures
identified in §63.804(g)(4)(vi).
(v) Owners or operators complying
with § 63.804(0(4) shall calculate each
site-specific operating parameter value
as the arithmetic average of the
maximum or minimum operating
parameter values, as appropriate, that
demonstrate compliance with the
standards, during the three test runs
required by § 63.805(c)(l).
(5) Owners or operators of an affected
source subject to the provisions of
§ 63.802 (a)(2) or (b)(2) that comply
through the procedures established in
§ 63.804 (b), (c)(l). or (e)(l), shall submit
an initial compliance status report, as
required by § 63.807fb), stating that
compliant contact adhesives are being
used by the affected source.
(6) Owners or operators, of an affected
source subject to the provisions of
§ 63.802 (a)(2)(ii) or (b)(2) that comply
through the procedures established in
§ 63.804-(c)(2) or (e)(2). shall
demonstrate initial compliance by:
(i) Submitting a monitoring plan that
identifies each operating parameter to
be monitored for the capture device and
discusses why each parameter is
appropriate for demonstrating
continuous compliance;
(ii) Conducting an initial performance
test as required under § 63.7 using the
procedures and test methods listed in
§ 63.7 and § 63.805 (c) and (d) or (e):
(iii) Calculating the overall control
efficiency (R) following the procedures
in §63.805 (d) or (e); and
(iv) Determining those operating
conditions critical to determining
compliance and establishing one or
•ncre operating parameters that will
ensure compliance with the standard.
iA) For compliance with a thermal
incinerator, minimum combustion
temperature shall be the operating
parameter.
(B) For compliance with a catalytic
incinerator equipped with a fixed
catalyst bed. the minimum gas
temperature both upstream and •*
downstream of the catalyst shall be the
operating parameter.
(C) For compliance with a catalytic
incinerator equipped with a fluidized
catalyst bed, the minimum gas
temperature upstream of the catalyst
bed and the pressure drop across the
catalyst bed shall be the operating
parameters.
(v) Owners or operators complying
with § 63.804(0(6) shall calculate each
site-specific operating parameter value
as the arithmetic average of the
maximum or minimum operating values
as appropriate, that demonstrate
compliance with the standards, during
the three test runs required by
§63.805(c)(l).
(7) Owners or operators of an affected
source subject to the provisions of
§ 63.802 (a)(3) or (b)(3) shall submit an
initial compliance status report, as
required by § 63.807(b), stating that
compliant strippable spray booth
coatings are being used by the affected
source.
(8) Owners or operators of an affected
source subject to the work practice
standards in § 63.803 shall submit an
initial compliance status report, as
required by § 63.807(b), stating that the
work practice implementation plan has
been developed and procedures have
been established for implementing the
provisions of the plan.
(g) Continuous compliance
demonstrations. (1) Owners or operators
of an affected source subject to the
provisions of § 63.802 (a)(l) or (b)(l)
that comply through the procedures
established in § 63.804 (a)(l) or (d)(l)
shall demonstrate continuous
compliance by submitting the results of
the averaging calculation (Equation 1)
for each month within that semiannual
period and submitting a compliance
certification with the semiannual report
required by §63.807(c).
(i) The compliance certification shall
state that the value of (E), as calculated
by Equation 1. is no greater than 1.0 for
existing sources or 0.8 for new sources.
An affected source is in violation of the
standard if E is greater than 1.0 for
existing sources or 0.8 for new sources
for any month. A violation of the
monthly average is a separate violation
of the standard for each day of operation
during the month, unless the affected
source can demonstrate through records
that the violation of the monthly average
can be attributed to a particular day or
days during the period.
(ii) The compliance certification shall
be signed by a responsible official of the
company that owns or operates the
affected source.
(2) Owners or operators of an affected
source-subject to the provisions of
§ 63.802 (a)(l) or (b)(l) that comply
through the procedures established in
§ 63.804 (a)(2) or (d)(2) shall
demonstrate continuous compliance by
using compliant coatings and thinners.
maintaining records that demonstrate
the coatings and thinners are compliant.
and submitting a compliance
certification with the semiannual report
required by § 63.807(c).
(i) The compliance certification shall
state that compliant stains, washcoats,
sealers, topcoats, basecoats, enamels.
and thinners. as applicable, have been
used each day in the semiannual
reporting period or should otherwise
identify the periods of noncompliance
and the reasons for noncompliance. An
affected source is in violation of the
standard whenever a noncompliant
coating, as demonstrated by records or
by a sample of the coating, is used.
(ii) The compliance certification shall
be signed by a responsible official of the
company that owns or operates the
affected source.
(3) Owners or operators of an affected
source subject to the provisions of
§ 63.802 (a)(l) or (b)(l) that are
complying through the procedures
established in § 63.804 (a)(2) or (d)(2)
and are applying coatings using
continuous coalers shall demonstrate
continuous compliance by following the
procedures in paragraph (g)(3) (i) or (ii)
of this section.
(i) Using compliant coatings, as
determined by the VHAP content of the
"coating in the reservoir and the VHAP
content as calculated from records.
using compliant thinners. and
submitting a compliance certification
with the semiannual report required by
§63.807(c).
(A) The compliance certification shall
state that compliant coatings have been
used each day in the semiannual
reporting period, or should otherwise
identify the days of noncompliance and
the reasons for noncompliance. An
affected source is in violation of the
standard whenever a noncompliant
coating, as determined by records or by
a sample of the coating, is used. Use of
a noncompliant coating is a separate
violation for each day the noncompliant
coating is used.
(B) The compliance certification shall
be signed by a responsible official of the
company that owns or operates the
affected source.
(ii) Using compliant coatings, as
determined by the VHAP content of the
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62944 Federal Register / Vol. 60. No. 235 / Thursday. December 7. 1995 / Rules and Regulations
coating in {he reservoir, using compliant
thinners. maintaining a viscosity of the
coating in the reservoir that is no less
than the viscosity of the initial coating
by monitoring the viscosity with a -
viscosity meter or by testing the
viscosity of the initial coating and
retesting the coating in the reservoir
each time solvent is added, maintaining
records of solvent additions, and
submitting a compliance certification
with the semiannual report required by
§63.807(c).
(A) The compliance certification shall
state that compliant coatings, as
determined by the VHAP content of the
coating in the reservoir, have been used
each day in the semiannual reporting
period. Additionally,'the certification
shall state that the viscosity of the
coating in the reservoir has not been less
than the viscosity of the initial coating,
that is, the coating that is initially mixed
and placed in the reservoir, for any day
in the semiannual reporting period.
(3) The compliance certification shall
be signed by a responsible official of the
company that owns or operates the
affected source.
(C) An affected source is in violation
of the standard when a sample of the as-
applied coating exceeds the applicable
limit established in § 63.804 (a)(2) or
(d)(2), as determined using EPA Method
311, or the viscosity of the coating in the
reservoir is less than the viscosity of the
initial coating.
(4) Owners or operators of an affected
source subject to the provisions of
§ 63.802 (a)(l) or (b)(l) that comply
through the procedures established in
§ 63.804 (a)(3) or (d)(3) shall
demonstrate continuous compliance by
installing, calibrating, maintaining, and
operating the appropriate monitoring
equipment according to manufacturer's
specifications. The owner or operator
shall also submit the excess emissions
and continuous monitoring system
performance report and summary report
required by § 63.807(d) and § 63.10(e) of
subpart A.
(i) Where a capture/control device is
used, a device to monitor each site-
specific operating parameter established
in accordance with § 63.804(f)(6)(i) is
required.
(ii) Where an incinerator is used, a
temperature monitoring device
equipped with a continuous recorder is
required.
(A) Where a thermal incinerator is
used, a temperature monitoring device
shall be installed in the firebox or in the
ductwork immediately downstream of
the firebox in a position before any
substantial heat exchange occurs.
(B) Where a catalytic incinerator
equipped with a fixed catalyst bed is
used, temperature monitoring devices
shall be installed in the gas stream
immediately before and after the
catalyst bed.
(C) Where a catalytic incinerator
equipped with a fiuidized catalyst bed
is used, a temperature monitoring
device shall be installed in the gas
stream immediately before the bed. In
addition, a pressure monitoring device
shall be installed to determine the
pressure drop across the catalyst bed.
The pressure drop shall be measured
monthly at a constant flow rate.
(iii) Where a carbon adsorber is used
one of the following is required:
(A) An integrating stream flow
monitoring device having an accuracy of
±10 percent, capable of recording the
total regeneration stream mass flow for
each regeneration cycle; and a carbon
bed temperature monitoring device,
having an accuracy of ±1 percent of the
temperature being monitored or ±0.5 °C,
whichever is greater, and capable of
recording the carbon bed temperature
after each regeneration and within 15
minutes of completing any cooling
cycle:
(B) An organic monitoring device.
equipped with a continuous recorder, to
indicate the concentration level of
organic compounds exiting the carbon
adsorber: or
(C) Any other monitoring device that
has been approved by the Administrator
in accordance with § 63.804(f)(4)(iv)(D).
(iv) Owners or operators of an affected
source shall not operate the capture or
control device at a daily average value
greater than or less than (as appropriate)
the operating parameter values. The
daily average value shall be calculated
as the average of all values for a
monitored parameter recorded during
the operating day.
(v) Owners or operators of an affected
source that are complying through the
use of a catalytic incinerator equipped
with a fiuidized catalyst bed shall
maintain a constant pressure drop.
measured monthly, acros|the catalyst
bed.
(vi) An owner or operator who uses a
control device not listed in § 63.004(0(4)
shall submit, for the Administrator's
approval, a description of the device,
test data verifying performance, and
appropriate site-specific operating
parameters that will be monitored to
demonstrate continuous compliance
with the standard.
(5) Owners or operators of an affected
source subject to the provisions of
§ 63.802 (a)(2) (i) or (ii) or (b)(2) that
comply through the procedures
established in §63.804 (b). (c)(l). or
(e)(l), shall submit a compliance
certification with the semiannual report
required by § 63.807(c).
(i) The compliance certification shall
.state that compliant contact and/or foam
adhesives have been used each day in
the semiannual reporting period, or
should otherwise identify each day
noncompliant contact and/or foam
adhesives were used. Each day a
noncompliant contact or foam adhesive
is used is a single violation of the
standard.
(ii) The compliance certification shall
be signed by a responsible official of the
company that owns or operates the
affected source.
(6) Owners or operators of an affected
source subject to the provisions of
§ 63.802 (a)(2)(ii) or (b)(2) that comply
through the procedures established in
§ 63.804 (c)(2) or (e)(2). shall
demonstrate continuous compliance by
installing, calibrating, maintaining, and
operating the appropriate monitoring
equipment according to the
manufacturer's specifications. The
owner or operator shall also submit the
excess emissions and continuous
monitoring system.performance report
and summary report required by
§ 63.807(d) and § 63.10(e) of subpart A
of this part.
(i) Where a capture/control device is
used, a device to monitor each site-
specific operating parameter established
in accordance with § 63.804(f)(6)(i) is
required.
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Federal Register / Vol. 60. No. 235 /Thursday. December 7, 1995V- Rules and Regulations '62945
(ii) Where an incinerator is used, a
temperature monitoring device
equipped with a continuous recorder is
required.
(AKWhere a thermal incinerator is
used, a temperature monitoring device
shall be installed in the firebox or in the
ductwork immediately downstream of •
the firebox in a position before any
substantial heat exchange occurs.
(B) Where a catalytic incinerator
equipped with a fixed catalyst bed is
used, temperature monitoring devices
shall be installed in the gas stream
immediately before and after the
catalyst bed.
(C) Where a catalytic incinerator
equipped with a fluidized catalyst bed
is used, a temperature monitoring
device shall be installed in the gas
stream immediately before the bed. In
addition, a pressure monitoring device
shall be installed to measure the
pressure drop across the catalyst bed.
The pressure drop shall be measured
monthly at a constant flow rate.
(iii) Where a carbon adsorber is used
one of the following is required:
(A)?ui integrating stream flow
monitoring device having an accuracy of
rlO percent, capable of recording the
total regeneration stream mass flow for
each regeneration cycle: and a carbon
bed temperature monitoring device,
having an accuracy of ±1 percent of the
temperature being monitored or ±0.5 "C.
whichever is greater, and capable of
recording the carbon bed temperature
after each regeneration and within 15
minutes of completing any cooling
cycle:
(B) An organic monitoring device,
equipped with a continuous recorder, to
indicate the concentration level of
organic compounds exiting the carbon
adsorber; or
(C) Any other monitoring device that
has been approved by the Administrator
in accordance with § 63.804(f)(4)(iv)(D).
(iv) Owners or operators of an affected
source shall not operate the capture or
control device at a daily average value
greater than or less than (as appropriate)
the operating parameter values. The
daily average value shall be calculated
as the average of all values for a
monitored parameter recorded during
the operating day.
(v) Owners or operators of an affected
source that are complying through the
use of a catalytic incinerator equipped
with a fluidized catalyst bed shall
maintain a constant pressure drop,
measured monthly, across the catalyst
bed.
(vi) An owner or operator using a
control device not listed in this section
shall submit to the Administrator a
descnotion of the device ;est data
verifying the performance of the device.
and appropriate operating parameter
values that will be monitored to
demonstrate continuous compliance
with the standard. Compliance using
this device is subject to the
Administrator's approval.
(7) Owners or operators of an affected
source subject to the provisions of
§ 63.802 (a)(3) or (b)(3) shall submit a
compliance certification with the
semiannual report required by
§63.807(c).
(i) The compliance certification shall
state that compliant strippable spray
booth coatings have been used each day
in the semiannual reporting period, or
should otherwise identify each day
noncompliant materials were used. Each
day a noncompliant strippable booth
coating is used is a single violation of
the standard.
(ii) The compliance certification shall
be signed-by a responsible official of the
company that owns or operates the
affected source.
(8) Owners or operators of an affected
source subject to the work practice
standards in § 63.803 shall submit a
compliance certification with the
semiannual report required by
§63.807(c).
(i) The compliance certification shall
state that the work practice
implementation plan is being*followed,
or should otherwise identify the
provisions of the plan that have not
been implemented and each day the
provisions were not implemented.
During any period of time that an owner
or operator is required to implement the
provisions of the plan, each failure to
implement an obligation under the plan
during any particular day is a violation.
(ii) The compliance certification shall
be signed by a responsible official of the
company that owns or operates the
affected source.
§ 63.805 Performance test methods.
(a) The EPA Method 311 of Appendix
A of part 63 shall be used in
conjunction with formulation data to
determine the VHAP content of the
liquid coating. Formulation data shall
be used to identify VHAP present in the
coating. The EPA Method 311 shall then
be used to quantify those VHAP
identified through formulation data. The
EPA Method 311 shall not be used to
quantify HAP such as styrene and
formaldehyde that are emitted during
the cure. The EPA Method 24 (40 CFR
pan 60, Appendix A) shall be used to
determine the solids content by weight
and the density of coatings. If it is
demonstrated to the satisfaction of the
Administrator that a coating does not
release VOC or HAP byproducts during
the cure, for example, all VOC and HAP
present in the coating is solvent, then
batch formulation information shall be
accepted. The owner or operator of an
affected source may requelt approval
from the Administrator to use an
alternative method for determining the
VHAP content of the coating. In the
event of any inconsistency between the
EPA Method 24 or Method 311 test data
and a facility's formulation data, that is,
if the EPA Method 24/311 value is
higher, the EPA Method 24/311 test
shall govern unless after consultation, a
regulated source could demonstrate to
the satisfaction of the enforcement
agency that the formulation data were
correct. Sampling procedures shall-
follow the guidelines presented in
"Standard Procedures for Collection of
Coating and Ink Samples for VOC
Content Analysis by Reference Method
24 and Reference Method 24A," EPA-
340/1-91-010. (Docket No. A-93-10.
Item No. IV-A-1).
(b) Owners or operators
demonstrating compliance in
accordance with § 63.804 (f)(4) or (f)(6)
and §63.804 (g)(4) or (g)(6), or
complying with any of the other
emission limits of § 63.802 by operating
a capture or control device shall
determine the overall control efficiency
of the control system (R) as the product
of the capture and control device
efficiency, using the test methods cited
in § 63.805(c) and the procedures in
§ 63.805 (d) or (e).
(c) When an initial compliance
demonstration is required by § 63.804
(f)(4) or (f)(6) of this'subpart. the
procedures in paragraphs (c)(l) through
(c)(6) of this section shall be used in
determining initial compliance with the
provisions of this subpart.
(1) The EPA Method 18 (40 CFR part
60. Appendix A) shall be used to
determine the HAP concentration of
gaseous air streams. The test shall
consist of three separate runs, each
lasting a minimum of 30 minutes.
(2) The EPA Method 1 or 1A (40 CFR
part 60. Appendix A) shall be used for
sample and velocity traverses.
(3) The EPA Method 2. 2A. 2C. or 2D
(40 CFR part 60, Appendix A) shall be
used to measure velocity and volumetric
flow rates.
(4) The EPA Method 3 (40 CFR part
60. appendix A) shall be used to analyze
the exhaust gases.
(5) The EPA Method 4 (40 CFR part
60. Appendix A) shall be used to •
measure the moisture in the stack gas.
(6) The EPA Methods 2. 2A. 2C. 2D.
3. and 4 shall be performed, as
applicable, at least twice during each
test period.
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62946 Federal Register / Vol. 60. No. 235 /Thursday. December 7. 1995 /Rules and Regulations
(d) Each owner or operator of an
affected source demonstrating
compliance in accordance with § 63.804
(f)(4) or (f)(6) shall perform a gaseous
•emission test using the following
procedures:
(1) Construct^ overall HAP
emission reduction system so that all
volumetric flow rates and total HAP
emissions can be accurately determined
by the applicable test methods specified
in § 63.805(c) (1) through (6);
(2) Determine capture efficiency from
the affected emission point(s) by
capturing, venting, and measuring all
HAP emissions from the affected
emission point(s). During a performance
test, the owner or'operator shall isolate
affected emission point(s) located in an
area with other nonaffected gaseous
emission sources from all other gaseous
emission point(s) by any of the
following methods:
i\) Build a temporary total enclosure
(see § 63.801) around the affected
emission point(s): or
(ii) Use the building that houses the
process as the enclosure (see § 63.801);
(iii) Use any alternative protocol and
test method provided they meet either
the requirements of the data quality
objective (DQO) approach or the lower
confidence level (LCL) approach (see
§63.801):
(iv) Shut down all nonaffected HAP
emission point(s) and continue to
exhaust fugitive emissions from the
affected emission point(s) through any
building ventilation system and other
room exhausts such as drying ovens. All
exhaust air must be vented through
stacks .suitable for testing; or
(v) Use another methodology
approved by the Administrator provided
it complies with the EPA criteria tor
acceptance under part 63. appendix A.
Method 301.
(3) Operate the control device with all
affected emission points that will
subsequently be delivered to the control
device connected and operating at
maximum production rate;
(4) Determine the efficiency (F) of the
control device using the following
equation:
F-.
j-i
(Equation 5)
(5) Determine the efficiency (N) of the
capture system using the following
equation:
di cdi
(Equation 6)
(6) For each affected source
complying with §.63.802(a)(l) in
accordance with § 63.804(a)(3),
compliance is demonstrated if the
product of (FxN)(!00) yields a value (R)
such that the value of Ex in Equation 2
is no greater than 1.0.
(7) For each new affected source
complying with § 63.802(b)(l) in
accordance with §63.804(d)(3).
compliance is demonstrated if the
product of (FxN)(100) yields a value (R)
such that the value of E% in Equation 4
is no greater than 0.8.
(8) For each affected source
complying with §63.802(a)(2)(ii) in
accordance with §63.804(c){2).
compliance is demonstrated if the
product of (FxNKlOO) yields a value (R)
such that the value of Gx in Equation
3 is no greater than 1.0.
(9) For each new affected source
complying with § 63.802(b)(2) in
accordance with §63.804(e)(2).
compliance is demonstrated if the
product of (FxN)dOO) yields a value (R)
such that the value of G^ in Equation
3 is no greater than 0.2.
(e) An alternative method to the
compliance method in § 63.805(d) is the
installation of a permanent total
enclosure around the affected emission
point(s). A permanent total enclosure
presents prima facia evidence that all
HAP emissions from the affected
emission point(s) are directed to the
control device. Each affected source that
complies using a permanent total
enclosure shall:
(1) Demonstrate that the total
enclosure meets the requirements in
paragraphs (e)(l) (i) through (iv). The
owner or operator of an enclosure that
does not meet these requirements may
apply to the Administrator for approval
of the enclosure as a total enclosure on
a case-by-case basis. The enclosure shall
be considered a total enclosure if it is
demonstrated to the satisfaction of the
Administrator that all HAP emissions
from the affected emission point(s) are
contained and vented to the control
device. The requirements for automatic
approval are as follows:
(i) The total area of all natural draft
openings shall not exceed 5 percent of
the total surface area of the total
enclosure's walls, floor, and ceiling;
(ii) All sources of emissions within
the enclosure shall be a minimum of
four equivalent diameters away from
each natural draft opening;
(iii) The average inward face velocity
(FV) across all natural draft openings
shall be a minimum of 3,600 meters per
hour as determined by the following
procedures:
(A) All forced makeup air ducts and
all exhaust ducts are constructed so that
the volumetric flow rate in each can be
accurately determined by the test
methods specified in § 63.805 (c)(2) and
(3). Volumetric flow rates shall be
calculated without the adjustment
normally made for moisture content:
and
(B) Determine FV by the following
equation:
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Federal Register / Vol. 60. No. 235 / Thursday. December 7. 1995 / Rules and Regulations 62947
FV =
I A,
k-l
(Equation 1}
(iv) All access doors and windows
whose areas are not included as natural
draft openings and are not included in
the calculation of FV shall be closed
during routine operation of the process.
(2) Determine the control device
efficiency using Equation (5). and the
test methods and procedures specified
in § 63.805 (c)(l) through (6).
(3) For each affected source
complying with § b3.302(a)(l) in
accordance with § 63.804(a)(3).
compliance is demonstrated if:
(i) The installation of a permanent
total enclosure is demonstrated (N=l):
(ii) The value of F is determined from
Equation (5); and
(iii) The product of (FxN)(100) yields
a value (R) such that the value of EK in
Equatioir-2 is no greater than 1.0.
(4) For each nsw affected source
complying with § 63.802fb)(l) in
accordance with §63.804(d)(3),
compliance is demonstrated if:
(i) The installation of a permanent
total enclosure is demonstrated (N = l);
(ii) The value of F is determined from
Equation (5); and
(iii) The product of (FxN)(lOO) yields
a value (R) such that the value of EK in
Equation 4 ij no greater than 0.8.
(S) For each affected source
complying with §63.802(a)(2)(ii) in
accordance with § 63.804(c)(2).
compliance is demonstrated if:
(i) The installation of a permanent
total enclosure is demonstrated (N=l);
(ii) The value of F is determined from
Equation (5); and
(iii) The product of (FxN)(100) yields
a value (R) such that the value of GK in
Equation 3 is no greater than 1.0.
(6) For each new affected source
complying with §63.802(b)(2) in
accordance with § 63.804(e)(2).
compliance is demonstrated if:
(i) The installation of a permanent
total enclosure is demonstrated (N=l);
(ii) The value of F is determined from
Equation (5): and
(iii) The product of (FxN)(lOO) yields
a value (R) such that the value of GK in
Equation 3 is no greater than 0.2.
§60.806 Recordkeeplng requirements.
(a) The owner or operator of an
affected source subject to this subpart
shall fulfill all recordkeeping
requirements of § 63.10 of subpart A.
according to the applicability criteria in
§ 63.800(d) of ihis'subpart.
(b) The owner or operator of an
affected source subject to the emission
limits in § 63.802 of this subpart shall
maintain records of the following:
(1) A certified product data sheet for
each finishing material, thinner, contact
adhesive, and strippable spray booth
coating subject to the emission limits in
§63. 802: and
(2) The VHAP content, in kg VHAP/
kg solids (Ib VHAP/lb solids), as
applied, of each finishing material and
contact adhesive subject to the emission
limits in §63.802; and
(3) The VOC content, in kg VOC/kg
solids (Ib VOC/lb solids), as applied, of
each strippable booth coating subject to
the emission limits in § 63.802 (a)(3) or
(c) The owner or operator of an
affected source following the
compliance method in § 63.804 (a)(l) or
(d)(l) shall maintain copies of the
averaging calculation for each month
following the compliance date, as well
as the data on the quantity of coatings
and thinners used that is necessary to
support the calculation of E in Equation
1.
(d) The owner or operator of a.n
affected source following the
compliance procedures of § 63.804
(f)(3)(ii) and (g)(3)(ii) shall maintain the
records required by § 63.806(b) as well
as records of the following:
(l) Solvent and coating additions to
the continuous coater reservoir
(2) Viscosity measurements: and
(3) Data demonstrating that viscosity
is an appropriate parameter for
demonstrating compliance.
(e) The owner or operator of an
affected source subject to the work
practice standards in § 63.803 of this
subpart shall maintain onsite the work
practice implementation plan and all
records associated with fulfilling the
requirements of that plan, including, but
not limited to:
(l) Records demonstrating that the
operator training program required by
§63.803(b) is in place:
(2) Records collected in accordance
with the inspection and maintenance
plan required by § 63.803(c);
(3) Records associated with the
cleaning solvent accounting system
required by §63.803(d):
(4) Records associated with the
limitation on the use of conventional air
spray guns showing total finishing
material usage and the percentage of
finishing materials applied with
conventional air spray guns for each
semiannual period as required by
§63.803(h)(5).
(5) Records associated with the
formulation assessment plan required
by §63.803(1): and
(6) Copies of documentation such as
logs developed to demonstrate that the
other provisions of the work practice
implementation plan are followed.
(f) The owner or operator of an
affected source following the
compliance method of § 63.804 (f)(4) or
(g)(4) shall maintain copies of the
calculations demonstrating that the
overall control efficiency (R) of the
control system results in the value of EK
required by Equations 2 or 4. records of
the operating parameter values, and
copies of the semiannual compliance
reports required by § 63.807(d).
Ig) The owner or operator of an
affected source following the
compliance method of § 63.804 (f)(6) or
(g](6). shall maintain copies of the
calculations demonstrating that the
overall control efficiency (R) of the
control system results in the applicable
value of CK calculated using Equation 3.
records of the operating parameter
values, and copies of the semiannual
compliance reports required by
§S3.307(d).
(h) The owner or operator of an
affected source subject to the emission
limits in §-63.802 and following the
compliance provisions of §63.804(0 (1).
(2). (3), (5). (7) and (8) and § 63.804(gJ
(1). (2). (3). (5). (7). and (8) shall
maintain records of the compliance
certifications submitted in accordance
with §63.807(c) for each semiannual
period following the compliance date.
(i) The owner or operator of an
affected source shall maintain records of
all other information submitted with the
compliance status report required by
§ 63.9(h) and § 63.807(b) and the
semiannual reports required by
§63.807(c).
(j) The owner or operator of an
affected source shall maintain all
records in accordance with the
requirements of § 63.10(b)(l).
§50.807 Reporting requirements.
(a) The owner or operator of an
affected source subject to this subpart
-------
62948 Federal Register / Vol. 60. No. 235 / Thursday; December 7, 199S 7 Rules and Regulations
shall fulfill all reporting requirements of
§63.7 through §63.10 of subpart A
(General Provisions) according to the
applicability criteria in § 63.800(d) of»
this subpart.
(b) The owner or operator of an
affected source demonstrating
compliance in accordance with
§63.804(f) (1). (2). (3). (5). (7] and (8)
shall submit the compliance status
report required by § 63.9(h) of subpart A
(General Provisions) no later than 60
days after the compliance date. The
report shall include the information
required by § 63.804(f) (1), (2). (3). (5).
(7), and (8) of this subpart.
(c) The owner or operator of an
affected source demonstrating
compliance in accordance with
§ 63.804(g) (1), (2). (3). (5). (7). and (8)
shall submit a report covering the
previous 6 months of wood furniture
manufacturing operations:
(1) The first report shall be submitted
30 calendar days after the end of the
first 6-month period following the "
compliance date.
(2) Subsequent reports shall be
submitted 30 calendar days after the end
of each 6-month period following the
first report.
(3) The semiannual reports shall
include the information required by
§ 63.804(g) (1). (2). (3). (5). (7), and (8).
a statement of whether the affected
source was in compliance or
noncompliance. and. if the affected
source was in noncompliance. the
measures taken to bring the affected
source into compliance.
(4) The frequency of the reports
required by paragraph (c) of this section
shall not be reduced from semiannually
regardless of the history of the owner's
or operator's compliance status.
(d) The owner or operator of an
affected source demonstrating
compliance in accordance with
§63.804(g) (4) and (6) of this subpart
shall submit the excess emissions and
continuous monitoring system
performance report and summary report
required by §63.10(e) of subpart A. The
report shall include the monitored
operating parameter values required by
§ 63.804(g) (4) and (6). If the source
experiences excess emissions, the report
shall be submitted quarterly for at least
1 year after the excess emissions occur
and until a request to reduce reporting
frequency is approved, as indicated in
§ 63.10(e)(3)(C). If no excess emissions
occur, the report shall be submitted
semiannually.
(e) The owner or operator of an
affected source required to-provide a
written notification under § 63.803(1)(4)
shall include in the notification one or
more statements that explains the
reasons for the usage increase. The
notification shall be submitted no later
than 30 calendar days after the end of
the annual period in which the usage
increase occurred.
§ 63.808 Delegation of authority.
(a) In delegating implementation and
enforcement authority to a State under
§ U2(d) of the Clean Air Act. the
authorities contained in paragraph (b) of
this section shall be retained by the
Administrator and not transferred to a
State.
(b) The authority conferred in
§63.804(f)(4)(iv) (D) and (E).
§ 63.804(g)(4)(iii)(C). § 63.804(g)(4)(vi).
§ 63.804(g)(6)(vi)( § 63.805(a).
§ 63.805(d)(2)(V), and § 63.805(e)(l)
shall not be delegated to any State.
§§63.809-63.819 [Reserved]
Tables to Subpart JJ to Part 63
TABLE 1.—GENERAL PROVISIONS APPLICABILITY TO SUBPART JJ
Reference
Applies to
subpart JJ
Comment
63.1 (a) Yes
63.!tb)(l) No „ Subpart JJ specifies applicability.
63.ltb)(2) Yes
63.1(D)(3) Yes
63.1(C)(1) No _ Subpart JJ specifies applicability.
63.Kc)(2) No „ Area sources are not subject to subpart JJ.
63.i(c)(i) Yes
63.1(0(5) Yes
63.i(e) Yes
63.2 Yes Additional terms are defined in 63.801 (a) of subpart JJ. When overlap between subparts A and JJ occurs.
subpart JJ takes precedence.
63.3 Yes Other units used in subpart JJ are defined in 63.801 (b).
63.4 Yes
63.5 Yes
63.6(a) „ Yes
63.6(b)(l) Yes
63.6(b)(2) Yes
63.6(b)(3) Yes
63.6(b)(4) „ NO May apply when standards are proposed under Section 112(0 of the CAA.
63.6(b)(5) Yes
63.6(b)(7) Yes
63.6(C)(1) Yes
63.6(c)(2) No
63.6(0(5) Yes
63.6(e)(i) Yes
63.6(e)(2) Yes
63.6(e)(3) Yes Applies only to affected sources using a control device to comply with the rule.
63.6(0(1) No Affected sources complying through the procedures specified in 63.804 (a)(l), (a)(2). (b). (c)(!) (d)(1).
(d)(2). (e)(l). and (e)(2) are subject to the emission standards at all times, including'periods of'startup!
shutdown, and malfunction.
63.6(0(2) Yes
63.6(0(3) Yes
63.6(g) Yes
63.6(h) No.
63.6 (i)(l)-(')(3) Yes
63.5(i)(J)(i) Yes
-------
Federal Register / Vul.' 60. No. 235 / Thursday. December 7. U95 / Rules and Regulations 62949
TABLE i.—G=NERAL PROVISIONS APPLICABILITY TO SUBPART JJ—Continued
Reference
Applies to
subpart JJ
Comment
53.6(0(16)
53.6(j)
63.7 .-
63.8
63.9(a)
63.9(13) ...:
63.9(C) -
53.9(d)
63.9(e)
63.9(1) .-
63.9(Q) .'.
53.9(h)
53.9CO
53.50)
53.10(3)
63.lO(b)(1)
63.10(b)(2)
63.lO(b)(3)
63.1C(C)
63.lO(d)(1)
53.lO(d)(2)
63.lO(d)(3)
53.lO(d)(4)
63.lO(d)(51
53.10(6)
53.10(f)
53.11
63.12-63.15
NO.
Yes
Yes
Yes
Yes
Yes _...
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes _
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes .
No
Yes
Yes
Yes
Yes
No
Yes
Applies only to affected sources using a control device to comply with the rule.
Applies only to affected sources using a control device to comply with the rule.
Existing sources are required to submit initial notification report within 270 days of the effective date.
Applies only to affected sources using a control device to comply with the rule.
Applies only to affected sources using a control device to comply with the rule.
63.9(h)(2)(ii) applies only to affected sources using a control device to comply with the rule.
Applies only to affected sources using a control device to comply with trie rule.
Applies only to affected sources using a control device to comply-with the rule.
Applies only to affected sources using a control device to comply with the rule.
Applies only to affected sources using a control device to comply with the rule.
TABLE 2.—LIST OF VOLATILE
HAZARDOUS AIR POLLUTANTS
TABLE 2.—LIST OF VOLATILE HAZARD-
OUS AIR POLLUTANTS—Continued
TABLE 2.—LIST OF VOLATILE HAZARD-
OUS AIR POLLUTANTS—Continued
Chemical name
Acetaldehyde
Acetamide
Acetonitnle
Acetophenone
2-Acetylaminofluorine
Acrolein
Acrylamide
Acrylic acid
Acrylonitrile
Allyl chlonde
4-Aminobiphenyl ,
Aniline
o-Anisidine
Benzene
Benzidine
Benzotnchloride
Benzyl chloride
Biphenyl
Sis(2-ethylhexyl)
(DEHP)
Bis(chloromethyl) ether
Bromoform
i .3-Butadiene
Caprolactam
Carbon disulfide
Carbon tetrachlonde
Carbonyl sulfide
Catechol
Chiorcaceoc acid
2-Chioroaceiophenone
C^iorobenzene
CMofolcrm
Cniorometnyl methyl etr.er
CMorcprene
phthalate
CAS No.
Chemical name
75070
60355
75058
98862
53963
107028
79061
79107
107131
107051
92671
62533
90040
71432
92875
98077
100447
92524
117817
542881
75252
106990
105602
75150
56235
463581
120809
79118
532274
108907
67663
107302
126998
Cresols (isomers and mixture)
o-Cresol - ~.
m-Cresol
p-Cresol
Cumene
2.4-D (2,4-Dichlorophenoxyacetic
acid, including salts and esters)
DOE (1,1-Oicnioro-2.2-bis (p-
chlorophenyl) ethyiene)
Diazomethane _
Dibenzofuran
1.2-Oibromo-3-chloropropane
Dibutylphthalate
i .4-Oichlorobenzene —
3.3'-Dichlorobenzidine
Dichloroethyl ether (Bis (2-
chloroethyf) ether)
1,3-Oichloropropene
Oiethanolamine
N,N-Oimethylaniline
Diethyl sulfate —
3,3'-Oimethoxybenzidine — _...
4-Oimethylaminoazobenzene
3.3'-Oimethylbenzidine
Dimethylcaroamoyl chloride
N,N-Oimethylformamide _...
1,1-Oimethylhydrazine
Dimethyl phthalate
Dimethyl sulfate
4.5-Dimtro-o-cresol. and salts
2.4-Dmitrophenol
2.4-Dinitrotoluene
1 ,-i-Dioxane (1.4-Diethyieneoxice)
l .2-Oipnenylhydrazine
CAS No.
Chemical name
1319773
95487
108394
106445
98828
94757
72559
334883
132649
96128
84742
106467
91941
111444
542756
111422
121697
64675
119904
60117
119937
79447
68122
57147
131113
77781
51285
121142
1239-1
122S57
Epichloronydnn (l-Chloro-2,3-
epoxypropane) —
1,2-Epoxybutane
Ethyl acrylate ._ _
Ethylbenzene —
Ethyl carbamate (Urethane)
Ethyl chloride (Chloroerhane)
Ethyiene dibromide (Di-
bromoethane)
Ethyiene dichloride (1,2-Oi-
chtoroethane)
Ethyiene glycol — _ —
Ethyiene oxide —
Ethytenethiourea _
Ethylidene dichloride (1,1-Oi-
chloroethane)
Formaldehyde _ _
Glycol ethers
Hexachlorobenzene
Hexachloro-i.3-butadiene „
Hexachloroethane
Hexametnylene-1,6-dusocyanate
Hexamethylphosphoramide
Hexane ............„.,..„_._... ..
Hydrazine
Hydroquinone
Isophorone — _.
Maleic anhydnde
Methanol
Methyl bromide (Bromomethane)
.Methyl chlonde (Chloromethane)
Methyl chloroform (l.i.i-Jn-
chloroethane)
Metnyl etnyl ketone (2-3utanone)
CAS No.
106898
106387
140865
100414
51796
75003
106934
107062
1072T1
7S2?8
96457
75343
50000
0
118741
87683
67721
8220W
680319
110543
3020 T 2
123319
78591
103316
6756'
74839
7-Z72
71555
78S33
-------
62950 Federal Register / Vol. 60. No. 235 / Thursday. December 7. 1995 / Rules and Regulations
TABLE 2.—LIST OF VOLATILE HAZARD- TABLE 2.—LIST OF VOLATILE HAZARD- TABLE 2.—LIST OF VOLATILE HAZARD-
OUS AIR POLLUTANTS—Continued ous AIR POLLUTANTS—Continued ous AIR POLLUTANTS—Continued
. Chemical name nac M« /"!hom«-al name, i~«e M,, r*Ha>vu/>*i name CAS No.
Methylhydrazine _.
Methyl iodide (lodomethane)
Methyl isobutyl ketone (Hexone) ..
Methyl isocyanate
Methyl methacrylate
Methyl tert-butyl ether ..
4.4'-Methylenebis (2-chloroaniline)
Methylene chloride (Dichloro-
methane)
4,4'-Methylenediphenyl
diisocyanate (MDI)
4.4--Methylenedianiline _ „
Naphthalene —
Nitrobenzene _
4-Nitrobiphenyl :...; _.
4-Nitrophenol „.
2-Nitropropane _
N-Nitroso-N-methylurea _.
N-Nitrosodimethylamine
N-Nitrosomorpholine „ _.
Pnenol .— „
p-?henylenediamine
Phosgene _
Phthalic anhydride _
Polychlorinated biphenyls
(Aroclors)
CAS No.
Chemical name
60344
74884
108101
624839
80626
1634044
101144
75092
101688
101779
91203
98953
92933
100027
79469
684935
62759
59892
108952
106503
75445
85449
1336363
Polycyclic Organic Matter* —
1,3-Propane sultone
beta-Propiolactone .„ _ —
Propionaldehyde .„._...«..-.—_._„
Propoxur (Baygon).
Propylene dichloride (1.2-Oi-
cnioropropane) ..... _._
Propylene oxide
1,2-Propylenimine (2-Methyl aziri-
dine)
Quinone
Styrene ...„...„..„....„„.............__.
Styrene oxide
2,3,7.8-Tetrachlorodibenzo-p-
dioxin ..............
1.1,2,2-Tetrachloroethane
Tetrachloroethylene
(Perchloroethyiene) J...
Toluene _.-. _.
2.4-Toluenediamine
Toluene-2,4-diisocyanate —
o-Toluidine
1,2.4-Trichlorobenzene _...
1,1,2-Trichloroethane
Trichloroethylene —
CAS No.
Chemical name
0
1120714
57578
123386
114261
78875
75569
75558
106514
100425
96093
1746016
79345
127184
108883
95807
584849
95534
120821
79005
79016
2.4.5-Trichlorophenol ._
.2.4,6-Trichlorophenol
Triethylamine —
TrifluraQn «•.... ..—.—.«——.•—•
2^.4-Trimethylpentane
Vinyl acetate
Vmyrbromide
Vinyl chloride
Vmylidene chloride (1.1-Oichloro-
ethylene) .—~-
Xylenes fisomers and mixture) —
oXylene
m-Xylene
p-Xylene
95954
88062
121448
1582098
540841
108054
593602
75014
75354
1330207
95476
108383
106423
'Includes mono- and di-ethers of ethylene
glycol, diethylene glycols and triethylene gty-
col; R-(OCHzCHi)RR-OR where:
n- 1,2, or 3.
R - aJkyl or aryrl groups
R' . R, H, or groups which, when removed.
yield glycol ethers with the structure: R-
,(OCH2CHj)n-OH. Polymers are excluded from
the glycol category.
'Includes organic compounds with more
than one benzene ring, and which have a boil-
ing point greater than or equal to 100*C.
TABLE 3.—SUMMARY OF EMISSION LIMITS
Emission point
Existing
source
New source
Finishing Operations:
(a) Achieve a weighted average VHAP content across all coatings (maximum kg VHAP/kg solids [Ib VHAP/lb .sol-
ids], as applied ..„.„„__ _ _....„ __ - _~- .................... „.
(b) Use compliant finishing materials (maximum kg VHAP/kg solids [Ib VHAP/lb solids), as applied):
—stains - — - «-« - - .. .
—washcoats „ -« ....
—sealers ..«. «• .—.
—topcoats -..._...
—basecoats „ ....- - —
- —enamels ....„..._ „ „ _
1—thinners (maximum % HAP allowable); or ._
(c) As an alternative, use control device: or _ — _
(d) Use any combination of (a), (b), and (c) _ - -
Cleaning Operations:
Strippable spray booth material (maximum VOC content, kg VOC/kg solids (Ib VOC/lb solids)) __
Contact Adhesives:
(a) Use compliant contact adhesives (maximum kg VHAP/kg solids (16 VHAP/lb solids), as applied) based on fol-
lowing criteria:
i. For aerosol adhesives, and for contact adhesives applied to nonpprous substrates _ „
ii. For loam adhesives used in products that meet flammability requirements
iii. For all other contact adhesives (including foam adhesives used in products that do not meet flammability
requirements); or _ — „.
(b) Use a control device : .-.
•1.0
M.O
*J>1.0
'1.0
'1.0
"1.0
«->1.0
10.0
'1.0
1.0
0.8
"NA
1.8
1.0
•1.0
'0.8
'1.0
'0.8
'0.8
•-00.8
10.0
«0.8
0.8
0.8
»NA
0.2
0.2
' The limits refer to the VHAP content of the coating, as applied.
•Washcoats. basecoats, and enamels must comply with the limits presented in this table if they are purchased premade, that is, if they are not
formulated onsite by thinning other finishing materials. If they are formulated onsite, they must be formulated using compliant finishing materials,
i.e.. those that meet the limits specified in this table, and thinners containing no more than 3.0 percent HAP by weight
-•The control device must operate at an efficiency that is equivalent to no greater than 1.0 kilogram (or 0.8 kilogram) of VHAP being emitted
from the affected emission source per kilogram of solids used.
« There is no limit on the VHAP content of these adhesives.
«The control device must operate at an efficiency that is equivalent to no greater than 1.0 kilogram (or 0.2 kilogram) of VHAP being emitted
from the affected emission source per kilogram of solids used.
-------
Federal Register / Vol. 60. No. 735 / Thursday. December 7. 1995 / Rules and Regulations 62951
TABLE 4.—POLLUTANTS EXCLUDED TABLE 4.—POLLUTANTS EXCLUDED
FROM USE IN CLEANING AND FROM USE IN CLEANING AND
TABLE 6.—VHAP OF POTENTIAL
CONCERN—Continued
HAS W0
Chemical name
N-Nitrosomorpholine ....
Dimethyl lormamide
Hexamethylphosphoramide
Acetamide
4 4--Methylenedianiline
o-Anisidine „ „.„_.
2.3,7.8-Tetrachtorodibenzo-p-
dioxin ._„ „.„„.
Beryllium salts
Benzidine .................. . .
N-Nitroso-N-methylurea .....'.
Bis(chloromethyl)ether _ „
Dimethyl carbamoyl chloride
Chromium compounds
(hexavalent) _.' —
1,2-Propylenimine (2-Metfiyl
aziridine) _ —
Arsenic and inorganic arsenic
compounds _ _
Hydrazine _ ..
1 1-Dimethyl hydrazioe , ,.
Beryllium compounds ._
i ,2-Oibromo-3-chloropropane
N-Nrtrosodimethylamine
Cadmium compounds
Benzo (a) pyrene . —
Polychlonnated biphenyls '
(Aroclors)
Heptachlor
3,3'-Dimethyl benzidine
Nickel subsulfide
Acrylamide _
Hexacniorobenzene
Chlordane
' ,3-Propane sultone
i 3-3utadiene ...
Nickel refinery dust ._
2-Acetylaminoflourine
3,3'-Oichlorobenzidine _
Lindane (hexachlorcyclohexane.
2,4-Toluene diarrune
Dichloroethyl ether (Bis(2-
chloroethyljether)
1 ,2-Oiphenylhydrazine _...
Toxaphene (chlorinated
camphene) ._. „._
2.4-Dinitrotoluene
3,3'-Dimethoxybenzidine
4.4'-Methylene bis(2thyl«n«
-------
62952 Federal Register / Vol. 60. No. 235 /Thursday. December 7. 1995 / Rules and Regulations
TABLE 6.—VHAP OF POTENTIAL
CONCERN—Continued
CAS NO.
79016
123911 ....
75070
75252
133062 ....
106898 ....
75092
127184 ....
53703
218019 ....
60117
56553
205992 ....
79469
542756 ....
57976
225514 ....
193395 ....
189559 ....
79345
91225 ......
75354
87683
82688
78591
79005
74873
67721
1582098 ..
1319773 ..
108394 ....
75343
95487
106445 ...
74884
100425 ...
107051 ...
334883 ...
95954
133904 ...
106887 ...
108054 _.
126998 ...
123319 ...
92933
Chemical name
Trichloroethylene.
1.4-Dioxane (1,4-
Diethyleneoxide).
Ace (aldehyde.
Bromoform.
Captan.
Epichlorohydrin.
Methylene chloride
(Oichloromethane).
Tetrachloroethylene
(Perchloroethytene).
Oibenz (ah) anthracene.
Chrysene.
Dimethyl aminoazobenzene.
Benzo (a) anthracene.
Benzo (b) lluoranthene.
2-Nlitropropane.
1,3-Dichloropropene.
7. 12-
Oimethylbenz(a)anthracene.
Benz(c)acridine.
lndeno(1 ,2.3-cd)pyrene.
1,2:7,8-Oibenzopyrene.
1,1,2,2-Tetrachloroethane.
Quinoline.
Vinylidene chloride (1,1-
Oichloroethylene).
Hexachlorobutadiene.
Pentachloronitrobenzene
(Quintobenzene).
Isophorone.
1,1.2-Trichloroethane.
Methyl chloride
(Chloromethane).
Hexachloroe thane.
Trifluralin.
Cresols/Cresylic acid (isomers
and mixture).
m-Cresol.
Ethyiidene dichloride (1.1-
Oichloroe thane).
o-Cresol.
p-Cresol.
Methyl iodide (lodomethane).
Styrene'.
Allyl chloride.
Oiazometnane.
2,4,5 - Trichlorophenol.
Chloramben.
1.2 - Epoxybutane.
Vinyl acetate.
Chloroprene.
Hydroquinone.
4-Nitrobiphenyl
"High-Concern" Pollutants
56382
13463393 .
60344
75218 _
151564
77781
107302
57578
100447
98077
107028
584849
75741
73002
Parathion.
Nickel Carbonyl.
Methyl hydrazine.
Elhylene oxide.
Ethylene imine.
Dimethyl sullate.
Chloromethyl methyl ether.
botn-Propiolactone.
Bonzyl chloride.
Bonzotnchloride.
Acrolein.
2,4 - Toluene diisocyanate.
Tetrametriyi lead.
Tetraethyl lead.
TABLE 6.—VHAP OF POTENTIAL
CONCERN—Continued
CAS No.
12108133.
624839 ....
77474 ......
62207765
10210681
79118 ,
534521 ....
101688
108952 ..-.
62384
98862 .......
108316 .....
532274 _...
51285
108864
98953
74839
75150 ..:....
121697
Chemical name
Methylcydopentadienyl man-
ganese.
Methyl isocyanate.
Hexachlorocyclopentadiene,
Fluomine.
Cobalt carbonyl.
Chloroacetic acid.
4,6-Dinitrc-o-cresol, and salts.
Methylene diphenyl
diisocyanate.
Phenol.
Mercury, (acetato-o) phenyl.
Acetophenone.
Maleic anhydride.
2-Chloroacetophenone.
2,4-Oinitrophenol.
2-Methyoxy ethanol.
Nitrobenzene. -
Methyl bromide
(Bromomethane).
Carbon disulflde.
N.N-Dimethylaniline.
"Unrankable" Pollutants
106514
123386
120809
85449 .
463581
132649
100027
540841
11422 ..
822060
Quinone.
Propionaldehyde.
Catechol.
Phthalic anhydride.
Carbonyl sulfide.
Oibenzofurans.
4-NitrophenoL
22.4-Trimethylpentane.
Diethanolamine.
Hexamethylene-1,6-dfisocyanate
Glycol ethers'
Polycyclic organic matter*
* - Currently an EPA weight of evidence
classification is under review.
»The EPA does not currently have an-offi-
cial weight-of-evidence classification for sty-
rene. For purposes ol this rule, styrene is
treated as a "nonthreshoid" pollutant (See>
data report form in appendix A of the hazard
ranking technical background document)
" Except for 2-ethoxy etnanol. ethylene gly-
col monobutyl ether, and 2-methoxy ethanol.
c Except lor benzo(b)fluoranttiene,
benzo(a)anthracene, benzo(a)pyrene. 7.12-
dimethylbenz(a)anthracene, benz(c)acridine,
chrysene, dibenz(ah) anthracene, 1.2:7,8-
dibenzopyrene, indeno(1,2.3-cd)pyrene, but in-
cluding dioxins and furans.
3. Appendix A of part 63 is amended
by adding Method 311 to read as
follows:
Appendix A to Part 63—Test Methods
Method 311—Analysis of Hazardous Air
Pollutant Compounds in Paints and Coatings
by Direct Injection Into a Cos Chromatograpb
I. Scope and Application
1.1 Applicability. This method is
applicable for determination of most
compounds designated by the U.S.
Environmental Protection Agency as volatile
hazardous air pollutants (HAP's) (See
Reference 1) that are contained in paints and
coatings. Styrene, ethyl acrylate. and methyl
methacrylate can be measured by ASTM D
48Z7-93 or ASTM D 47*7-97
can be measured by ASTM PS 9-94 or
D 1979-91. Toluene diisocyanate can oe
measured in urethane prepolymersby ASTM
D 3432-«9. Method 311 applies onlv »those
volatile HAP's which are'added to tn«
coating when it is manufactured, not to those
which may form as the costing cures
(reacti on products or cure volaUlesJ. A
separate or modified test procedure mu*tjM
used to measure these reaction products^
cure volatiles in order to determine the total
volatile HAP emissions from » coating. Cure
volatiles are a significant component of the
total HAP content of some coatings. The term
"coating" used in this method shall be
understood to mean paints and coatings.
1.2 Principle. The method uses the
principle of gas chromatographic separation
and quantification using a detector that
responds to concentration differences.
Because there are many potential analytical
systems or sets of operating conditions that
may represent useable methods for
determining the concentrations of the
compounds cited in Section 1.1 in the
applicable matrices, all systems that employ
this principle, but differ only in details of
equipment and operation, may be used as
alternative methods, provided that the
prescribed quality control, calibration, and
method performance requirements are met
Certified product data sheets (CPDS) may
also include information relevant to the
analysis of the coating sample including, but
not limited to. separation column, oven
temperature, carrier gas. injection port
temperature, extraction solvent, and internal
standard.
2. Summary of Method
Whole coating is added to
dimethylformamide and a suitable internal
standard compound is added. An aliquot of
the sample mixture is injected onto a
chromatographic column containing a
stationary phase that separates the analytes
from each other and from other volatile
compounds contained in the sample. The
concentrations of the analytes are determined
by comparing the detector responses for the
sample to the responses obtained using
known concentrations of the analytes.
3. Definitions (Reserved]
4. Interferences
4.1 Coating samples of unknown
composition may contain the compound
used as the internal standard. Whether or not
this is the case may be determined by
following the procedures of Section 11 and
deleting the addition of the internal standard
specified in Section U.S.3. If necessary, a
different internal standard may be used.
4.2 The CC column and operating
conditions developed for one coating
formulation may not ensure adequate
resolution of target analytes for other coating
formulations. Some formulations may
contain nontarget analytes that coelu'te with
target analytes. If there is any doubt about the
identification or resolution of any gas
chromatograph (CC) peak, it may be
necessary to analyze the sample using a
different CC column or different CC
operating conditions.
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Federal Register / Vol. 60, No. 235 / Thursday. December 7, 1995 / Rules and Regulations 62953
•i.3 QoBS-cnntaminalion may occur
whcr.eva hi^h-level and low-lrvnl samples
are anntaMi sequentially. The order of
: coruiit'.uns existing nt the source
sampled.
6.2 Laboratory Equipment and Supplies-. -
6.2.1 Gas Chromaiograph (CO. Any
instrument equipped with a flame ionization
detector and capable of being temperature
programmed may be used. Optionally, other
types of detectors (e.g.. a mass spectrometer).
and Any necessary interfaces, may be used
provided that the detector system yields an
Appropriate and reproducible response to the
unalvtes in the injected sample. Autosampler
injection may be used, if available.
6.2.2 Recorder. If available, an electronic
data station or integrator may be used to
record the gas chromatogram and associated
data. If a strip chart recorder is used, it must
meet the following criteria: A 1 to 10
millivolt (mV) linear response with a full
scale response time of 2 seconds or less and
a maximum noise level of ±0.03 percent of
full scale. Other types of recorders may be
used as appropriate to the specific detector
installed provided that the recorder has a full
scale response time of 2 seconds or less and
a maximum noise level of ±0.03 percent of
full scale.
6.2.3 Column. The column must be
constructed of materials that do not react
with components of the sample (e.g.. fused
silica, stainless steel, glass). The column
should be of appropriate physical
dimensions (e.g.. length, internal diameter)
and contain sufficient suitable-siatioMry
phase to allow separation of the anaiytes.
DB-5. DB-Wax, and FFAP columns are
commonly used for paint analysis; however,
it is the responsibility of each analyst to
select appropriate columns and stationary
phases.
6.2.4 Tube and Tube Fittings. Supplies to
connect the GC and gas cylinders.
6.2.S Pressure Regulators. Devices used to
regulate the pressure between gas cylinders
and the GC
6.2.6 Flow Meter. A device used to
determine the carrier gas flow rate through
the GC Either a digital flow meter or a soap
film bubble meter may be used to measure
gas flow rates.
6.2.7 Septa. Seals on the GC injection
port through which liquid or gas samples can
be injected using a syringe.
6.2.8 Liquid Charging Devices. Devices
used to inject samples into the GC such as
clean and graduated 1. 5. and 10 microliter
(lil) capacity syringes.
6.2.9 Vials. Containers that can be sealed
with a septum in which samples may be
prepared or stored. The recommended size is
:5 ml capacity. Mininerr* valves have been
found satisfactory and are available from
Pierce Chemical Company, Rockford. Illinois.
6.2.10 Balance. Device used to determine
the weights of standards and samples. An
analytical balance capable of accurately
weighing to 0.0001 g is required.
~ Reagents and Standards
~ \ Purity of Reagents. Reagent grade
chrmicals shall be ussd in all tests. Unless
otherwise specified, all reagents shall
conform tn the specifications of the
Committee on Analytical Reagents of the
American Chemical Society, where such
specifications ;irn iivnilablu. Other grades miy
br used provided it is first ascertained thbt
ihc reagent is of sufficient purity to permit
its use without lessening the accuracy of
determination.
'.2 Carrier Cos. Helium carrier gas shall
have a purity of 99.995 percent or higher.
High purity nitrogen may also be used. Other
carrier gases that are appropriate for the
column system and analyte may also be used.
Ultra-high purity gradi* hydrogen gas and
zero-grade air shall be used for the flame
ionization detector.
7.3 Dimethylformamide (DMF). Solvent
for all standards and samples. Some other
suitable solvent may be used if DMF is not
compatible with the sample or coelutes with
a target analyte.
Note: DMF may coelute with ethylbenzene
or p-.tylene under the conditions described
in the note -under Section 6.2.3.
7.4 latnrnal Standard Materials. The
internal standard material is used in the
quantitation of the anaiytes for this method.
It shall be gas chromatography
spectrophotometric Quality or. if this grade is
not available, the highest quality available.
Obtain the assay for the internal standard
material and maintain at that purity during
use. The recommended internal standard
material is l-propanol: however, selection of
an appropriate internal standard material for
the particular coating and GC conditions
used Is the responsibility of each analyst.
7.5 Reference Standard Materials. The
reference standard materials are the
chemicals cited in Section 1.1 which are of
known identity and purity and which are
used to assist in the identification and
quantification of the anaiytes of this method.
They shall be the highest quality available.
Obtain the assays for the reference standard
materials And maintain at those purities
during use.
. ,i6 Siock Reference Standards. Stock
reference standards are dilutions of the
reference standard materials that may b«
used on a daily basis to prepare calibration
standards, calibration check standards, and
quality control check standards. Stock
reference standards may be prepared from
the reference standard materials or purchased
as certified solutions.
7.6.1 Stock reference standards should b«
prepared in dimethylformamide for each
analyte expected in the coating samules to be
analyzed. The concentrations of anaiytes in
the stock reference standards are not
specified but must be adequate to prepare the
calibration standards required in the method
A stock reference standard may contain more
than one analyte provided all anaiytes are
chemically compatible and no anaiytes
coelute. The actual concentrations prepared
must be known to within 0.1 percent (e,g..
0.1000 : 0.0001 g/g solution). The following
procedure is suggested. Place about 35 ml of
dimetrrylform;imido into a tared ground-glass
stoppered 30 ml volumetric flask. Weigh the
flask :o th* nearest O.l mg. Add 125 g of the
reference standard material and reweigh the
flask. Dilu'.e to volume with
dimcthylformnmido and reweigh. Stopper the
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62954 Federal Register / Vol. 60. No. 235 / Thursday. December 7. 1995 / Rules and Regulations
flask and mix the contents by inverting the
uask several timi.-s. Calculate the
concentration in grams per gram of solution
from ihe net gain in weights, correcting for
tfttrassaycd purity of the reference standard
material.
Note: Although a glass-stoppered
volumetric flask is convenient, any suitable
glass container may be used because stock
reference standards are prepared by weight.
7.6.2 Transfer the stock reference
standard solution into one or more Teflon-
sealed screw-cap bottles. Store, with minimal
headspacc. at - 10*C to 0*C and protect from
light.
7.6.3 Prepare fresh stock reference
standards every six months, or sooner if
analysis results from daily calibration check
standards indicate a problem. Fresh stock
reference standards for very volatile HAP's
may have to be prepared more frequently.
7.7 Calibration Standards. Calibration
standards are used to determine the response
of the detector to known amounts of
reference material. Calibration standards
must be prepared at a minimum of three
concentration levels from the stock reference
standards (see Section 7.6). Prepare the
calibration standards in dimethylformamide
(see Section 7.3). The lowest concentration
standard should contain a concentration of
analyte equivalent either to a concentration
of no more than 0.01% of the analyte in a
coating or to a concentration that is lower
than the actual concentration of the analyte
in the coating, whichever concentration is
higher. The highest concentration standard
should contain a concentration of analyte
equivalent to slightly more than the highest
concentration expected for the analyte in a
coating. The remaining calibration standard
should contain a concentration of analyte
roughly at the midpoint of the range defined
by the lowest and highest concentration
calibration standards. The concentration
range of the standards should thus
correspond to the expected range of analyte
concentrations in the prepared coating
samples (see Section 11.5). Each calibration
standard should contain each analyte for
detection by this method expected in the
actual coating samples (e.g.. some or all of
the compounds listed in Section 1.1 may be
included). Each calibration standard should
also contain an appropriate amount of
internal standard material (response for the
internal standard material is within 25 to 75
percent of full scale on the attenuation
setting for the particular reference standard
concentration level). Calibration Standards
should be stored for 1 week only in sealed
vials with minimal headspace. If the stock
reference standards were prepared as
specified in Section 7.6. the calibration
standards may be prepared by either
weighing each addition of the stock reference
standard or by adding known volumes of the
stock reference standard and calculating the
mass of the standard reference material
added. Alternative 1 (Section 7.7.1) specifies
the procedure to be followed when the stock
reference standard is added by volume.
Alternative 2 (Section 7.7.2) specifies the
procedure to be followed when the stock
reference standard is added by weight.
Mole: To assist with determining the
appropriate amount of internal standard to
add. as required hure and in other sections
of this method, the analyst may find it
advantageous to prepare u curve showing the
area response versus the amount of internal
standard injected into the CC
7.7.1 Preparation Alternative 1.
Determine the amount of each stock reference
standard and dimethylformamide solvent
needed to prepare approximately 25 ml of the
specific calibration concentration level
desired. To a tared 25 ml vial thai can be
sealed with a crimp-on or Mininerf* valve.
add the total amount of dimethylformamide
calculated to be needed. As quickly as
practical, add the calculated amount of each
stock reference standard using new pipets (or
pipet tips) for each stock reference standard.
Reweigh the vial and seal it. Using the
known weights of the standard reference
materials per ml in the stock reference
standards, the volumes added, and the total
weight of all reagents addedlo the vial.
calculate the weight percent of each standard
reference material in the calibration standard
prepared. Repeat this process for each
calibration standard to be prepared.
7.7.2 Preparation Alternative 2.
Determine the amount of each stock reference
standard and dimethylformamide solvent
needed to prepare approximately 25 ml of the
specific calibration concentration level
desired. To a tared 25 ml vial that can be
sealed with a crimp-on or Mininerr" valve.
add the total amount of dimethylformamide
calculated to be needed. As quickly as
practical, add the calculated amount of a
stock reference standard using a new pipet
(or pipet tip) and reweigh the vial. Repeat
this process for each stock reference standard
to be added. Seal the vial after obtaining the
final weight. Using the known weight
percents of the standard reference materials
in the stock reference standards, the weights
of the stock reference standards added, and
the total weight of all reagents added to the
vial, calculate the weight percent of each
standard reference material in the calibration
standard prepared. Repeat this process for
each calibration standard to be prepared.
8. Sample Collection, Preservation.
Transport, and Storage
8.1 Copies of material safety data sheets
(MSDS's) for each sample should be obtained
prior to sampling. The MSDS's contain
information on the ingredients, and physical
and chemical properties data. The MSDS's
also contain recommendations for proper
handling or required safety precautions.
Certified product data sheets (CPDS) may
also include information relevant to the
analysis of the coating sample including, but
not limited to. separation column, oven
temperature, carrier gas. injection port
temperature, extraction solvent, and internal
standard.
8.2 A copy of the blender's worksheet can
be requested to obtain data on the exact
coating being sampled. A blank coating data
sheet form (see Section 18) may also be used.
The manufacturer's formulation information
from the product data sheet should also be
obtained.
8.3 Prior to sample collection, thoroughly
mix the coating to ensure that a
representative, homogeneous sample is
obtained. It is preferred that this be
accomplished using a coating can shaker or
similar device: however, when necessary..
this may be accomplishedusing mechanical
agitation or circulation systems.
8.3.1 Water-thinned coatings tend to
incorporate or entrain air bubbles if stirred
too vigorously: mix these types of coatings
slowly and only as long as necessary to
homogenize.
8.3.2 Each component of multicomponent
coatings that harden when mixed must be
sampled separately. The component mix
ratios must be obtained at the facility at the
time of sampling and submitted to the
analytical laboratory.
8.4 Sample Collection. Samples must be
collected in a manner that prevents or
minimizes loss of volatile components and
that does not contaminate the coating
reservoir. A suggested procedure is as
follows. Select a sample collection container
which has a capacity at least 25 percent
greater than the container in which the
sample is to be transported. Make sure both
sample containers are clean and dry. Using
clean, long-handled tongs, turn the sample
collection container upside down and lower
it into the coating reservoir. The mouth of the
sample collection container should be at
approximately the midpoint of the reservoir
(do not take the sample from the top surface).
Turn the sample collection container over
and slowly bring it to the top of the coating
reservoir. Rapidly pour the collected coating
into the sample container, filling it
completely. It is important to fill the sample
container completely to avoid any loss of
vo la tiles due to volatilization into the
headspace. Return any unused coating to the
reservoir or dispose as appropriate.
Note: If a company requests a set of
samples for its own analysis, a separate set
of samples, using new sample containers,
should be taken at the same time.
8.5 Once the sample is collected, place
the sample container on a firm surface and
insert the inner seal in the container by
placing the seal inside the rim of the
container, inverting a screw cap, and
pressing down on the screw cap which will
evenly force the inner seal into the container
for a tight fit Using clean towels or rags,
remove all residual coating material from the
outside of the sample container after
inserting the inner seal. Screw the cap onto
the container.
8.5.1 Affix a sample label (see Section 18)
clearly identifying the sample, date collected,
and person collecting the sample.
8.5.2 Prepare the sample for
transportation to the laboratory. The sample
should be maintained at the coating's
recommended storage temperature specified
on the Material Safety Data Sheet, or. if no
temperature is specified, the sample should
be maintained within the range of 5°C to
38'C
8.9 The shipping container should adhere
to U.S. Department of Transportation
specification DOT 12-B. Coating samples are
considered hazardous materials; appropriate
shipping procedures should be followed.
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Federal Register'/ Vol. 60, No. 235 / Thursday. December:/. 1P(^ ' ° iles and Regulations £2955
9. Quality Control
9.1 Uiborntnrius using this method
should operate a fomiiil quality control
program. The minimum requirements of the
program should consist of an initial
demonstration of laboratory capability and an
ongoing analysis of blanks and quality
control samples to evaluate and document
quality data. The laboratory must maintain
records to document the quality of the data
generated. When results indicate atypical
method performance, a quality control check
standard (see Section 9.4) must be analyzed
to confirm that the measurements were
performed in an in-control mode of
operation.
9.2 Before processing any samples, the
analyst must demonstrate, through analysis
of a reagent blank, that there are no
interferences from the analytical system.
glassware, and reagents that would bias the
sample analysis results. Each time a set of
analytical samples is processed or there is a
change in reagents, a reagent blank should be
processed as a safeguard against chronic
laboratory contamination. The blank samples
should be carried through all stages of the
sample preparation and measurement steps.
9.3 Required instrument quality control
parameters are found in the following
sections:
9.3.1 T-Baseline stability must be
demons&ated to be <5 percent of full scale
using the procedures given in Section 10.1.
9.3.2 The GC calibration is not valid
unless the retention time (RT) for each
analyte at each concentration is within ±0.05
min of the retention time measured for that
analyte in the stock standard.
9.3.3 The retention time (RT) of any
sample analyte must be within ±0.05 min of
the average RT of the analyte in the
calibration standards for the analyte to be
considered tentatively identified.
9.3.4 The GC system must be calibrated
as specified in Section 10.2.
9.3.5 A one-point daily calibration check
must be performed as specified in Section
10.3.
9.4 To establish the ability to generate
results having acceptable accuracy and
precision, the analyst must perform the
following operations.
9.4.1 Prepare a quality control check
standard (QCCS] containing each analyte
expected in the coating samples at a
concentration expected to result in a
response between 25 percent and 75 percent
of the limits of the calibration curve when
the sample is prepared as described in
Section 11.5. The QCCS may be prepared
from reference standard materials or
purchased as certified solutions. If prepared
in the laboratory, the QCCS must be prepared
independently from the calibration
standards.
9.4.2 Analyze three aliquots of the QCCS
according to the method beginning in Section
11.5.3 and calculate the weight percent of
each analyte using Equation 1. Section 12.
_9.4.3 Calculate the mean weight percent
(XI for each analyte frorn the three results
obtained in Section 942.
9 4 -i Calculate the percent .icruracy for
each nnalyte using the known concentrations
(Ti) in the QCCS usmy Equation 3. Section
12.
9.4.5 Calculate the percent relative
standard deviation (percent RSD) for each
analyte using Equation 7. Section 12.
substituting the appropriate values fur the
relative response factors (RRF's) insatd . .
equation.
9.4.6 If the percent accuracy (Section _
9.4.4) for all analytes is within the range 90
percent to 110 percent and the percent RSD
(Section 9.4.5) Cor all analyte* is S20 percent.
system performance is acceptable and sample
analysis may begin. If these criteria are not
met for any analyte. then system performance
is not acceptable for that analyte and the test
must be repeated for those analytes only.
Repeated failures indicate a general problem
with the measurement system that must be
located and corrected. In this case, the entire
test, beginning at Section 9.4.1. must be
repeated after the problem is corrected.
9.5 Great care must b« exercised to
maintain the integrity of all standards. It is
recommended that all standards be stored at
- 10 *C to 0 *C in screw-cap amber-glass
bottles with Teflon liners.
9.6 Unless otherwise specified, all
weights are tp be recorded within 0.1 mg.
10. Calibration and Standardization.
10.1 Column Baseline Drift. Before each
calibration and series of determinations and
before the daily calibration check, condition
the column using procedures developed by
the laboratory or as specified by the column
supplier. Operate the GC at initial (i.e.. before
sample injection) conditions on the lowest
attenuation to be used during sample
analysis. Adjust the recorder pen to zero on
the chart and obtain a baseline, for at least
one minute. Initiate the GC operating cycle
that would be used for sample analysis. On
the recorder chart, mark the pen position at
the end of the simulated sample analysis
cycle. Baseline drift is defined as the absolute
difference in the pen positions at the
beginning and end of the cycle in the
direction perpendicular to the chart
movement. Calculate the percent baseline
drift by dividing the baseline drift by the
chart width representing full-scale deflection
and multiply the result by 100
10.2 Calibration of GC Bring all stock
standards and calibration standards to room
temperature while establishing the CC at the
determined operating conditions.
10.2.1 Retention Times (RT's) for
Individual Compounds.
Mole: The procedures of this subsection are
required only for the initial calibration.
However, it is good laboratory practice to
follow these procedures for some or all
analytes before each calibration. The
procedures were written for chromatograms
output to a strip chart recorder. More modern
instruments (eg., integrators and electronic
data stations) determine and print out or
display retention times automatically.
The RT for each analyte should bo
determined before calibration. This provides
a positive identification for each peak
observed from the calibration standards.
Iniect an appropriate volume (see Note in
Section 11.5.2) of one of the stock reference
stanrinrris into the gas chromatograph and
record on the chart the pen position at thn
time of the injection (see Section 7 K. i j.
2-:. .:<'; in aliquo; of rfce stock reference
standard as required in dimothylfannmide
to achieve a concentration thai will malt ia
an on-$cale response. Operate the gas
<~hroma:ogntph according to ifayjatarmiaed
procedures. Select the peak(i) rMt
correspond to the analyted) land internal
standard, if used! and measure th» rataatioa
timers). If a chart recorder i* used, maanjni
the distanced) on th» chart from the'"(•"<'"»
point to the peak maxima. HUM dteuoa*.
divided by the chart speed, are-d*ftned as the
RT's of the analytes in question. Repeat this
process for each of the stock reference
standard solutions.
Note: If gas chromatography with mass
spectrometer detection (GC-MS) is used, a
stock reference standard may contain a group
of analytes. provided all analytes are
adequately separated during Che analysis.
Mess spectral library matching can be used
tu identify the analyte associated with each
peak in the gas chromatogram. The retention.
f.rr.e for the analyte then becomes the
reter.uon time of its peak in the
chromatogram.
10.2.2 Calibration. The GC must be
calibrated using a minimum of three
concentration levels of each potential
analyte. (See Section 7.7 for instructions oa
preparation of the calibration standards.)
Beginning with the lowest concentration
level calibration standard, carry out the
analysis procedure as described beginning to:
Sec:;on 11.7. Repeat the procedure for each
progressively higher concentration level until
all calibration standards have been analyzed.
10.2.2.1 Calculate the RT's for the
internal standard and for each analyte in tb*
calibration standards at each concentration
level as described in Section 10.2.1. The RT's
for the internal standard must not vary by
more lhan 0.10 minutes. Identify each
analyte by comparison of the RT's for peak
maxima to the RT's determined ia Section
10.: •..
10.2.2.2 Compare the retention times
(RT's) for each potential analyte in the
calibration standards for each concentrattatt
level ;o the retention times determined in
Secv.on 10.2.1. The calibration is not valid
unless all RT's for ail analytes meet the
criteria given in Section 9.3.2.
10.2.2.3 Tabulate the area responses and
the concentrations for the internal standard
ar.ri each analyte in the calibration standards.
Calculate the response factor for the internal
stanaard (Rfa) and the response factor for
each compound relative to the internal
standard (RRF) for each concentration lewe£
using Equations 5 and 6. Section 12,
1CU.2.4 Using the RRFs from the
calibration, calculate the percent relative
standard deviation (percent RSD) for each
analyte in the calibration standard using
Equation 7. Section 12. The percent RSD for
each individual calibration analyte must be
less than 15 percent. This criterion must be
met in order for the calibration to be valid.
If the criterion is met. the mean RRF's;
determined above are to be used until the
next calibration.
10.3 Daily Calibration Checks. The
calibration curve (Section 10.2.2! must be
checked .ind venfieit .11 least once each day
that s.imoies are an.ilvzed. This is
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62956 Federal Register / Vol.-60. No. 235 / Thursday, December 7. 1995 / Rules and Regulations
accomplished by analyzing a calibration
standard that is at a concentration near the
midpoint of the working range and
performing the checks in Sections 10.3.1.
10.3.2. and 10.3.3.
10.3.1 For each analyte in the calibration
standard, calculate the percent difference in
the RRF from the last calibration using
Equation 8. Section 12. If the percent
difference for each calibration analyte is less
than 10 percent, the last calibration curve is
assumed to be valid. If the percent difference
for any analyte is greater than 5 percent, the
analyst should consider this a warning limit
If the percent difference for any one
calibration analyte exceeds 10 percent.
corrective action must be taken. If no source
of the problem can be determined after
corrective action has been taken, a new three-
point (minimum) calibration must be
generated. This criterion must be met before
quantitative analysis begins.
10.3.2 If the RFi. for the internal standard
changes by more than ±20 percent from the
last daily calibration check, the system must
be inspected for malfunctions and
corrections made as appropriate.
10.3.3 The retention times for the internal
standard and all calibration check analytes
must be evaluated. If the retention time for
the internal standard or for any calibration
check analyte changes by more than 0. Id ruin
from the last calibration, the system must be
inspected for malfunctions and corrections
made as required.
33. Procedure
ll.l All samples and standards must be
allowed to warm to room temperature before
analysis. Observe the given order of
ingredient addition to minimize loss of
volatiles.
11.2 Bring the CC system to-the
determined operating conditions and
condition the column as described in Section
10.1.
Note: The temperature of the injection port
may be an especially critical parameter.
Information about the proper temperature
may be found on the CPDS.
11.3 Perform the daily calibration checks
as described in Section 10.3. Samples are not
to be analyzed until the criteria in Section
10.3 are met.
11.4 Place the as-received coating sample
on a paint shaker, or similar device, and
shake the sample for a minimum of 5.
minutes to achieve homogenization.
1 1.5 Note: The steps in this section must
be performed rapidly and without
interruption to avoid loss of volatile organics.
These steps must be performed in a
laboratory hood free from solvent vapors. All
weights must be recorded to the nearest 0.1
mg.
11.5.1 Add 16 g of diraethylformaraide to
each of two tared vials (A and B) capable of
being septum sealed.
1 l.S.2 To each vial add a weight of
coating that will result in the response for the
major constituent being in the upper half of
the linear range of the calibration curve.
Note: The magnitude of the response
obviously depends on the amount of sample
injected into the GC as specified in Section
11.8. This, volume must be the same as used
for preparation of the calibration curve.
otherwise shifts in compound retention times
may occur. If a sample is prepared that
results in a response outside the limits of the
calibration curve, new samples must "be
prepared: changing the volume injected to
bring the response within the calibration
curve limits is not permitted.
11.5.3 Add a weight of internal standard
to each vial (A and B) that will result in the
response for the internal standard being
between 25 percent and 75 percent of the
linear range of the calibration curve.
11.5.4 Seal the vials with crimp-on or
Mininert" septum seals.
11.6 Shake the vials containing the
prepared coating samples for 60 seconds.
Allow the vials to stand undisturbed for ten
minutes. If solids have not settled out on the
bottom after 10 minutes, then centrifuge at
1.000 rpm for 5 minutes. The analyst also has
the option of injecting the sample without
allowing the solids to settle.
11.7 Analyses should be conducted in the
following order, daily calibration check
sample, method blank, up to 10 injections
from sample vials (i.e.. one injection each
from up to five pairs of vials.*which
corresponds to analysis of 5 coating samples).
11.8 Inject the prescribed volume of
supernatant from the calibration check
sample, the method blank, and the sample
vials onto the chromatographic column and
record the chromatograms while operating
the system under the specified operating
conditions.
Note: The analyst has the option of
injecting the unseparated sample.
12. Data Analysis and Calculations
12.1 Qualitative Analysis. An analyte (e.g.,
those cited in Section 1.1) is considered
tentatively identified if two criteria are
satisfied: (1) elution of the sample analyte
within ±0.05 min of the average GC retention
time of the same analyte in the calibration
standard: and (2) either (a) confirmation of
the identity of the compound by spectral
matching on a gas chromatograph equipped
with a mass selective detector or (b) elution
of the sample analyte within ±0.05 min of the
average GC retention time of the same analyte
in the calibration standard analyzed on a
dissimilar GC column.
12.1.1 The RT of the sample analyte must
meet the criteria specified in Section 9.3.3.
12.1.2 When doubt exists as to the
identification of a peak or the resolution of
two or more components possibly comprising
one peak, additional confirmatory techniques
(listed in Section 12.1) must be used.
12.2 Quantitative Analysis. When an
analyte has been identified, the
quantification of that compound will be
based on the internal standard technique.
12.2.1 A single analysis consists of one
injection from each of two sample vials (A
and B) prepared using the same coating.
Calculate the concentration of each identified
analyte in the sample as follows:
HAPwl% =
where:
— =—
(AU){RRFX)(WI)
Eq. (1)
= weight percent of the analyte in coating.
A, = Area response of the analyte in the sample.
W.B = Weight of internal standard added to sample, g.
A;, = Area response of the internal standard in the sample.
RRFX = Mean relative response factor for the analyte in the calibration standards.
W, = Weight of coating added to the sample solution, g.
12.2.2 Report results for duplicate analysis
(sample vials A and B) without correction.
12.3 Precision Data. Calculate the percent
difference between the measured
concentrations of each analyte in vials A and
B as follows.
12.3.1 Calculate the weight percent of the
analyte in each of the two sample vials as
described in Section 12.2.1.
12.3.2 Calculate the percent difference for
each analvte as:
=100x
IA.-B,
Eq. (2)
where A, and B, are the measured
concentrations of the analvte in vials A and
B.
-------
f Federal Register / Vol. m No. 235 / Thursday. December 7. 1995 / Rules and Regulations 62957
12.4 Calculate the percent accuracy for
inalytes in the QCCS (See Section 9.4) as
follows:
% Accuracy^
, . .
— — tq. (j)
where X. is the mean measured value and T, calibration standards (See Section 10.2.2.2)
is the known true value of the analyte in the as follows-
QCCS.
12.5 Obtain retention times (RTs) from
data station or integrator or. for
chromatograms from a chart recorder.
calculate the RT's for analytes in the
RT'
Distance from injection to peak maximum
Recorder chart speed
Eq. (4)
l2.6~Calculate the response factor for the
internal standard (See Section 10.2.2.3) as
follows:
, Eq. (5)
where:
Au s Area response of the internal
standard.
Cu = Weight percent of the internal
standard.
12.7 Calculate the relative response factors
for analytes in the calibration standards (See
Section 10.2.2.3) as follows:
where:
RRF. =•
RF, C.
Eq. (6)
RRF, = Relative response factor for an
individual analyte.
A. » Area response of the analyte being
measured.
C, = Weight percent of the analyte being
measured.
12.8 Calculate the percent relative standard
deviation of the relative response factors tor
analytes in the calibration standards (See
Section 10.2.2.4) as follows:
%RSD = 100x-
where:
n-1
RRF.
Eq. (7)
n - Number of calibration concentration levels used for an analyte.
^ = Individual RRF for an analyte.
RRFX = Mean of all RRF's for an analyte.
12.9 Calculate the percent difference in the calibration curve and the daily calibration
relative response factors between the checks (See Section 10.3) as follows:
- RRF
% Difference =
where:
RRF.
- x 1 00 Eq. (8)
RRF = mean relative response factor from last calibration.
RRF = relative response factor from calibration check standard.
13. Measurement of Reaction Byproducts
That are HAP. [Reserved]
14. Method Performance. {Beservedl
15. Pollution Prevention. [Reservedl
16. Waste Management
16.1 The coating samples and laboratory
standards and reagents may contain
compounds which require management as
hazardous waste. It is the laboratory s
responsibility to ensure all wastes are
managed in accordance with all applicable
laws and regulations.
16.2 To avoid excessive laboratory
obtain only enough sample for laboratory
analysis.
-------
62958
Federal Register / Vol. 60, No. 235 / Thursday. December 7, 1995 / Rules and Regulations
16.3 It is recommended that discarded
waste coating solids, used rags, used paper
towels, and other nonglass or nonsharp waste
materials be placed in a plastic bag before
disposal. A separate container, designated
"For Sharp Objects Only." is recommended
for collection of discarded glassware and
other sharp-edge items used in the
laboratory. It is recommended that unused or
excess samples and reagents be placed in a
solvent-resistant plastic or metal container
with a lid or cover designed for flammable
liquids. This container should not be stored
in the area where analytical work is
performed. It is recommended that a record
be kept of all compounds placed in the
container for identification of the contents
upon disposal.
17. References
1. Clean Air Act Amendments, Public Law
101-549. Titles I-XI. November. 1990.
2. Standard Test Method for Water Content
of Water-Reducible Paints by Direct Injection
into a Gas Chromatograph. ASTM
Designation 03792-79.
3. Standard Practice for Sampling Liquid
Paints and Related Pigment Coatings. ASTM
Designation O392S-81.
4. Standard Test Method for Determination
of Dichloromethane and 1.1.1-
Trichloroethane in Paints and Coatings by
Direct Injection into a Gas Chromatograph.
ASTM Designation 04457-65.
5. Standard Test Method for Determining
the Unreacted Monomer Content of Latexes
Using Capillary Column Gas
Chromatography. ASTM Designation 04627-
93.
6. Standard Test Method for Determining
Unreacted Monomer Content of Latexes
Using Gas-Liquid Chromatography. ASTM
Designation D 4747-87.
7. Method 301—"Field Validation of
Pollutant Measurement Methods from
Various Waste Media." 40 CFR 63. Appendix
A.
Society. Washington. DC For suggestions on
the testing of reagents not listed by the
American Chemical Society, see "Reagent
Chemicals and Standards" by Joseph Rosin.
D. Van Nostrand Co.. Inc.. New York. NY and
the "United States Pharmacopeia."
18. Tables. Diagrams. Flowcharts, and
Validation Data
Agency: .
Inspector _
Date/Time: • .
. Sample ID»: .
Source ID: .
Coating Name/Type: . -.
Plant Witness:
8. "Reagent Chemicals. American Chemical
Society Specifications." American'Chemical Source:
Type Analysis Required:
Special Handling:
Sample Container Label
Coating Data
Date:
Data
Coating:
Supplier Name _
Name and Color of Coating _ _
Type of Coating (primer, c^anvwt, 9'C ) ,,-,-- , , , ,,,.,,.,, ,,..,.,,.„,,....,,.,
Identification Number for Coating ... ._ _ ...
Coating Density (Ibs/gal) _
Total Volatiles Content (wt percent) „
Water Content (wt percent) _ _
Exempt Solvents Content (wt percent) _
VOC Content (wt percent) _
Solids Content (vol percent) . _ _ ......
Diluent Properties:
Name.
Identification Number _ _ „
Diluent Solvent Density (Ibs/gal)
VOC Content (wt percent) _-.'..„
Water Content (wt percent) .._ _
Exempt Solvent Content (wt percent) „ _
Diluent/Solvent Ratio (gal diluent solvent/gal coating)
Sample 10 No.
Sample 10 No.
Stock Reference Standard
Name of Reference Material:
Supplier Name:
Lot Number.
Purity:
Name of Solvent
Dimethylformamide
Supplier Name:
Lot Number:
Purity:
Material:
Date Prepared:
Prepared By:
Notebook/page no.:
PREPARATION INFORMATION
1. Weight Empty Flask g
2. Weight Plus DMF ,g
PREPARATION INFORMATION—
Continued
3. Weight Plus Reference ,g
Material. .
4. Weight After Made to .g
Volume.
5. Weight DMF (lines 2- ,g
1+3-4).
6. Weight Ref. Material ,g
(lines 3-2).
7. Corrected Weight of Ref- ,g
erence Material (line 6
times purity). Notebook/page:
8. Fraction Reference Ma- -'- - - -
terial in Standard (Line 7
*• Line 5) soln.
9. Total Volume ol Stand- . ml
ard Solution.
10. Weight Reference Ma- ,g/ml
terial per ml of Solution
(Line 7 - Line 9).
PREPARATION INFORMATION—
Continued
Laboratory ID No. for this
Standard.
ExDiration Date for this
Standard.
CALIB RATION STANDARD
Date Prepared:
Date Expires:
Prepared By:
,.9/9 Calibration Standard Identification No.:
Final Weight Flask Plus
Reagents.
Weight Empty Flask
Total Weight Of Reagents
-------
•* Federal «RegisterW Vul.'60.-*Mo. .235 / Thursday.* December 7. 1395 A Rules and Regulations 62959
Analyle name •
-
Stock ref-
erence stand-
ard 10 No.
Amount o< stock reference standard added (by volume or by
weight)
Volume
added, ml
Amount in
standard, g/ml
Weight added,
g
Amount in
standard, g/g
soln
Calculated
weight analyte
added, g
.
Weight per-
cent anaiyte in
calibraDon
standard •
•
* Include internal standard(s).
»Weight percent « weight analyte added * total weight of reagents.
Quality Control Check Standard
Date Prepared:
Date Expires:
Prepared By:
Notebook/page:
Quality Control Check Standard
Identification No.:
PREPARATION INFORMATION
Final Weight Flask Plus .g
Reagents.
Weight Empty Rask ,g
Total Weight Of Reagents ,g
Analyte name •
Stock ref-
erence stand-
ard ID No.
Amount of stock reference standard added (by volume or by
weight)
Volume
added, ml
Amount in
standard, g/ml
Weight added.
g
Amount in
standard, g/g
soln
Calculated
weight analyte.
added, g
Weight per-
cent anatyte in
QCC stand-
ard"
•Include internal Standard(s).
"Weight percent-weight analyte added •* total weight ol reagents.
Quality Control Check Standard Analysis
Date OCCS Analyzed:
OCCS Identification No.
Analyst:
QCCExpiration Date:
ANALYSIS RESULTS
Analyte
Weight percent determined
Run 1
Run 2
Run 3
Mean Wt
percent
Percent
accuracx
Percent
RSD
Meets criteria in Section
9.4.6
Percent
accuracy
Percent
RSD
-------
6296Q Federal Register / Vol. 60, No. 235 / Thursday. December 7. 1995 7 'Rules and Regulations
Calibration of Gas Chromatograph
Calibration Date:
Calibrated By:
PART 1.—RETENTION TIMES FOR INDIVIDUAL ANALYTES
Analyte
- ,
Stock stand-
ard. ID No.
• Recorder chart speed
Inches/min.
cm/mm.
Distance (ram injection point to
peak maximum
Inches
Centimeters
Retention
time, minutes "
• Retention time=distance to peak maxima-i-chart speed.
CALIBRATION OF GAS CHROMATOGRAPH Calibrated By:
Calibration Date:
PART 2.—ANALYSIS OF CALIBRATION STANDARDS
Analyte
Name:
Cone, in STD .
Area Response
RT . .
Name:
Cone, in STD .... „
Area Response . ._ . .. _ „
RT ..
Name:
Cone, in STD . _
Area Response _. _
RT ... .
Name:
Cone, in STD _
Area Response
RT _ „
Name:
Cone, in STD ....
Area Response _
RT _
Name:
Cone, in STD . _.
Area Response „.
RT .„ __ . . ._
Name:
Cone, in STD ... ..
Area Response _• . . _ _
RT
Name:
Cone, in STD
Area Response _ _
RT ..._. . ....
Internal Standard Name:
Cone. In STD „ _
Area Response „
RT
Calib. STD ID
No.
Calib. STD ID
No.
Calib.. STD ID
No.
Calibration of Cas Chiomatograph
Calibration Date:
Calibrated By:
-------
.Federal Register / Vol. 60. No. 235-/-Thursday. December 7. 1595 J Rules and Regulations 62961
PART 3.—DATA ANALYSIS FOR CALIBRATION STANDARDS
Analyie
Name:
RT
RF
Name:
RT
RF
Name:
RT
RF _
Name:
RT ......
RF
Name:
RT
RF ..
Name:
RT ..._
RF
Name:
RT „ „
RF
Calib. STD ID
Calib. STD ID
Calib. STD ID
Mean
percent RSD
ol RF
Is RT within
±0.05 mm of
RT for stock?
(Y/N)
Is percent
RSO <30% (Y/
N)
Diilv Calibration Check
Analyst:
Date: Calibration
Analyte
Check Standard ID No.: Expiration D«
Retention Time (RT)
Last
Tnis
Difference '
ite:
Response Factor (RF)
Last
This
Difference"
'Retention tome (RT) change (difference) must be less than ±0.10 minutes.
» Response factor (RF) change (difference) must be less than 20 percent for each analyte and for the internal standard
Sample Analysis
Vial A ID No.: _
Vial B ID No.: _
Analyzed By:
Date:
Samole preparation information
Measured:
wt empty viaJ - - -
wt plus DMF
wt plus sample ~
wt plus internal
standard
Calculated:
wt DMF
v/t sample
wi internal standard
Vial A (g)
Vial 8 (g)
-------
32*62 Federal Register / Vol. 60, No. 235 / Thursday^December 7, 1995 / Rules and Regulations
ANALYSIS RESULTS: DUPLICATE SAMPLES
Analyle
Internal Standard _ _ _.
Area response
Vial A
Vial B
RF
Wt
• Vial A
percent in sample
Vial B
Average
[FR Doc. 95-29358 Filed 12-6-95: 8:45 am]
BILLING CODE S5SO-SO-P
-------
APPENDIX G
EXAMPLE REPORTING FORMS
-------
INITIAL NOTIFICATION REPORT
Applicable Rule: 40 CFR Part 63, Subpart JJ-National Emission Standards for Wood
Furniture Manufacturing Operations
I. Print or type the following information for each plant in which wood furniture
manufacturing operations are performed:
Owner/Operator/Title
Street Address
City State Zip Code
Plant Name
Plant Phone Number ;
Plant Contact/Title
Plant Address (if different than owner/operator's):
Street Address
City State Zip Code
2. Provide a brief description of the wood furniture manufacturing process used at your
facility. (Include preliminary identification of each emission point or source of emissions
within the wood furniture manufacturing operations, e.g., spray guns, spray booths, etc.)
3. Estimate of annual use of coatings, adhesives, cleaning, and washoff materials: gal
4. Indicate your anticipated compliance approach:
D Compliant coatings
D Averaging
D Control device
D Combination:
5. Print or type the name of the Responsible Official for the plant:(Optional)
(Name) (Title)
G-l
-------
INITIAL NOTIFICATION REPORT (continued)
A Responsible Official can be:
>• The president, vice-president, secretary, or treasurer of the company that owns the
plant;
»• The owner of the plant;
+ The plant engineer or supervisor;
*> A government official if the plant is owned by the Federal, State, city, or county
government; or
+ A ranking military officer if the plant is located on a military base.
I certify the information contained in this report to be accurate and true to the best of my
knowledge.
(Signature of Responsible Official) (Date)
G-2
-------
INITIAL COMPLIANCE STATUS REPORT
Applicable Rule: 40 CFR Part 63, Subpart JJ-National Emission Standards for Wood
Furniture Manufacturing Operations
1. Print or type the following information for each plant in which wood furniture
manufacturing operations are performed:
Owner/Operator/Title
Street Address
City State Zip Code
Plant Name
Plant Phone Number
Plant Contact/Title
Plant Address (if different than owner/operator's):
Street Address
City State Zip Code
2. Indicate whether the facility is a new or existing source:
D New source (construction commenced on or after December 6, 1994)
D Existing source
3. Indicate the facility's compliance date: / /
4. Indicate the facility's compliance approach:
D Compliant Coatings/Adhesives
D The facility is using compliant coatings, thinners, and/or adhesives.
D Compliant Coatings with continuous coaters
D The facility is using compliant coatings, as determined by the VHAP content of
the coating in the reservoir and the calculated VHAP content, and compliant
thinners
D The facility is using compliants coatings and thinners and monitoring the viscosity
of the coating hi the reservoir, and attach data demonstrating the relationship
between viscosity and VHAP content of the coating.
D Averaging
D A copy of the averaging calculation for the month in which the compliance date
fell is attached.
G-3
-------
INITIAL COMPLIANCE STATUS REPORT (continued)
D Control Device
D A copy of the facility's monitoring plan and results from the initial performance
test are attached.
D Combination of methods
Indicate combination of compliance methods being used:
D Requirements for both methods are attached.
5. Work Practice Standards
n The facility has developed a work practice implementation plan and has established
procedures for implementing the provisions of the plan.
6. Print or type the name of the Responsible Official for the plant:
(Name) (Title)
A Responsible Official can be:
*- The president, vice-president, secretary, or treasurer of the company that owns the
plant;
»• The owner of the plant;
> The plant engineer or supervisor;
*• A government official if the plant is owned by the Federal, State, city, or county
government; or
>• A ranking military officer if the plant is located on a military base.
I certify the information contained in this report to be accurate and true to the best of my
knowledge.
(Signature of Responsible Official) (Date)
G-4
-------
CONTINUOUS COMPLIANCE STATUS REPORT
Applicable Rule: 40 CFR Part 63, Subpart JJ~National Emission Standards for Wood
Furniture Manufacturing Operations
1. Print or type the following information for each plant in which wood furniture
manufacturing operations are performed.
Owner/Operator/Title
Street Address
City State Zip Code
Plant Name
Plant Phone Number
Plant Contact/Title
Plant Address (if different than owner/operator's):
Street Address
City State Zip Code
2. Indicate the beginning and ending dates of the reporting period:
juining: / / Ending: / /
3. Check all that apply for the facility's compliance approach.
For facilities using a compliant coatings/adhesives approach:
D Each day in this reporting period, compliant thinners, coatings, and/or
adhesives were used.
Indicate below on what dates any noncompliant coatings (including strippable spray
booth coatings), thinners, or adhesives were used during the reporting period and
why:
G-5
-------
CONTINUOUS COMPLIANCE STATUS REPORT (continued)
For a compliant coatings approach using continuous coaters:
D Compliant coatings (as determined by the VHAP content of the coating in the
reservoir and the VHAP content of the coating as calculated from records)
and compliant thinners were used each day in this reporting period.
D Compliant coatings (as determined by the VHAP content of the coating in the
reservoir) and compliant thinners were used each day in the reporting period
and the viscosity of the coating hi the reservoir has not been less than the
viscosity of the initial coating.
Indicate below on what dates any noncompliant-coatings or thinners were used during
the reporting period and why:
For facilities using an averaging approach:
D This facility has met the emission limits specified in 40 CFR 63.802 for
finishing operations every month by using an averaging approach. A copy of
the averaging calculation for each month within this reporting period is
attached.
D This facility has not met the monthly average emission limits specified in
40 CFR 63.802 for finishing operations. A copy of the averaging calculation
for each month within this reporting period is attached and the months for
which this facility was out of compliance are noted below (note that a
violation of the monthly average is a separate violation of the standard for
each day of operation, unless the affected source can demonstrate through
records that the violation can be attributed to a particular day or days during
the period):
G-6
-------
CONTINUOUS COMPLIANCE STATUS REPORT (continued)
For facilities using a control device approach:
D Capture or control devices have not been operated at daily average values
greater than or less than (as appropriate) the operating parameter values
established in the initial performance test.
D The following capture or control devices were operated at daily average
values greater than or less than (as appropriate) the operating parameters
established on the following dates:
For facilities using a combination of methods:
Indicate combination of compliance methods being used (averaging and control
device or compliant coatings and control device), attach appropriate requirements
and check appropriate boxes above for both methods:
4. Work Practice Standards
D During this reporting period, the work practices in 40 CFR 63.803 were followed
in accordance with the work practice implementation plan and the inspection and
maintenance plan for this source.
D During this reporting period, the work practices in 40 CFR 63.803 were not
followed in accordance with the work practice implementation plan and the
inspection and maintenance plan for this source.
G-7
-------
CONTINUOUS COMPLIANCE STATUS REPORT (continued)
If the inspection and maintenance plan or work practice implementation plan was not
followed during the reporting period, please provide an explanation of the reasons for not
following the provisions of the plan, an assessment of whether any excess emissions
and/or parameter monitoring exceedances are believed to have occurred, and a copy of
the appropriate records documenting that the inspection and maintenance plan or work
practice implementation plan was not followed. Please state whether either plan is being
revised accordingly.
5. Please describe any changes in monitoring, processes, or controls since the last reporting
period:
6. Print or type the name of the Responsible Official for the plant:
(Name) (Title)
A Responsible Official can be:
»• The president, vice-president, secretary, or treasurer of the company that owns the
plant;
*• The owner of the plant;
> The plant engineer or supervisor;
»• A government official if the plant is owned by the Federal, State, city, or county
government; or
>• A ranking military officer if the plant is located on a military base.
I certify the information contained in this report to be accurate and true to the best of my
knowledge.
(Signature of Responsible Official) (Date)
G-8
-------
TECHNICAL REPORT DATA
(PLEASE READ INSTRUCTIONS ON THE REVERSE BEFORE COMPLETING)
I. REPORT NO.
EPA^453/R-97-002
3. RECIPIENTS ACCESSION NO.
4, TITLE AND SUBTITLE
A GUIDE TO THE WOOD FURNITURE CTG AND NESHAP
5. REPORT DATE
SEPTEMBER 1997
6. PERFORMING ORGANIZATION CODE
7. AUTHORS)
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
U.S. ENVIRONMENTAL PROTECTION AGENCY/OAQPS
EMISSION STANDARDS DIVISION/INFORMATION TRANSFER
AND PROGRAM INTEGRATION DIVISION
RESEARCH TRIANGLE PARK, NC 27711
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
DIRECTOR/OFFICE OF AIR QUALITY PLANNING & STANDARDS
OFFICE OF AIR AND RADIATION
U.S. ENVIRONMENTAL PROTECTION AGENCY
RESEARCH TRIANGLE PARK, NC 27711
13. TYPE OF REPORT AND PERIOD COVERED
14. SPONSORING AGENCY CODE
EPA/200/04
15. SUPPLEMENTARY NOTES
EPA WORK ASSIGNMENT MANAGER: PAUL ALMODOVAR (919) 541-0283;
DEBORAH ELMORE (919) 541-5437
16. ABSTRACT
THIS DOCUMENT PROVIDES GUIDANCE TO OWNERS AND OPERATORS OF WOOD FURNITURE
MANUFACTURING OPERATIONS ON HOW TO COMPLY WITH THE REQUIREMENTS OF THE NATIONAL
EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS AND THE CONTROL TECHNIQUES GUIDELINES.
IT INCLUDES SECTIONS ON RULE APPLICABILITY, FINAL RULE REQUIREMENTS, AND ALTERNATIVE
CONTROL OPTIONS. IN ADDITION, THIS DOCUMENT CONTAINS EXAMPLE REPORTING FORMS AND
EXAMPLE RECORDKEEPING FORMS.
17.
KEY WORDS AND DOCUMENT ANALYSIS
a. DESCRIPTORS
AIR POLLUTION
GUIDANCE DOCUMENT
HAZARDOUS AIR POLLUTANTS
NATIONAL EMISSION STANDARDS
WOOD FURNITURE
b. IDENTIFIERS/OPEN ENDED TERMS
AIR POLLUTION CONTROL
c. COSATI RELD/GROUP
18. DISTRIBUTION STATEMENT
RELEASE UNLIMITED
UNCLASSIFIED
21. NO. OF PAGES
167
22. PRICE
UNCLASSIFIED
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